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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
) 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
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
) 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
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
) 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 Net Loss and the Partnership for Federal
Leon Black
PERSONNet Profit
ORGANIZATIONFederal, State
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
ORGANIZATION
Wilmington
LOCATIONCertificate of Formation
ORGANIZATIONthe United States Treasury
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION