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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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
Entities connected to both Net Profit and Net Loss and the Partnership any Net Loss
Leon Black
PERSONNet Profit
ORGANIZATIONFederal, 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
ORGANIZATIONthe Offered Interests
ORGANIZATIONPurchase
LOCATIONEach Partner's
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION