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change shall be done so as to minimize, to the extent possible, any differences in amounts that would otherwise be distributable to a Partner. (c) Each Partner's Capital Account shall have an initial balance equal to the amount of cash and the value of any securities or other property constituting such Partn
ns and thereby cause the respective Capital Accounts of the Partners to be in the amounts (or as close thereto as possible) they would have been if Net Profit and Net Loss (and such other items of income, gain, deduction and loss) had been allocated without reference to the Regulatory Allocations. In general, the Par
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
Entities connected to both Each Partner's and Net Profit and Net Loss
Net Profit
ORGANIZATIONLeon Black
PERSONFederal, State
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONAccounting Period
ORGANIZATIONReliance
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONPurchase
LOCATIONthe Offered Interests
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION