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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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
Entities connected to both Net Profit and Net Loss and the Revised Limited Partnership Act
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
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION