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all property contributed by such Partner (net of liabilities that are secured by such contributed property), (ii) such Partner's allocated share of Net Profit and other items of income and gain of the Partnership, and (iii) the amount of any Partnership liabilities assumed by such Partner. Each 7 EFTA005
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
all property contributed by such Partner (net of liabilities that are secured by such contributed property), (ii) such Partner's allocated share of Net Profit and other items of income and gain of the Partnership, and (iii) the amount of any Partnership liabilities assumed by such Partner. Each 7 lkst*-U
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
all property contributed by such Partner (net of liabilities that are secured by such contributed property), (ii) such Partner's allocated share of Net Profit and other items of income and gain of the Partnership, and (iii) the amount of any Partnership liabilities assumed by such Partner. Each 7 Dock US
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
Entities connected to both Net Profit and the Partnership for Federal

Wilmington
LOCATIONLeon Black
PERSONNet Profit and Net Loss
ORGANIZATIONthe Person or Persons
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONAccounting Period
ORGANIZATIONReliance
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONthe Offered Interests
ORGANIZATIONPurchase
LOCATIONEach Partner's
ORGANIZATIONCertificate of Formation
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION