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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
t forth on Schedule A holding an interest in the Partnership (whether as a General Partner or a Limited Partner) and such other Persons admitted as Partners of the Partnership in accordance with Article IX. "Partnership Interest" means the ownership interest of a Partner (whether a General Partner or a Limited Partner) in
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
t forth on Schedule A holding an interest in the Partnership (whether as a General Partner or a Limited Partner) and such other Persons admitted as Partners of the Partnership in accordance with Article IX. "Partnership Interest" means the ownership interest of a Partner (whether a General Partner or a Limited Partner) in
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
t forth on Schedule A holding an interest in the Partnership (whether as a General Partner or a Limited Partner) and such other Persons admitted as Partners of the Partnership in accordance with Article IX. "Partnership Interest" means the ownership interest of a Partner (whether a General Partner or a Limited Partner) in
Entities connected to both Net Profit and Net Loss and Partners of the Partnership
Net Profit
ORGANIZATIONLeon Black
PERSONReliance
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONthe Offered Interests
ORGANIZATIONPurchase
LOCATIONEach Partner's
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION