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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
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
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
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
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
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
gain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Members proportionately to the allocation of Net Profit and Net Loss among the Members. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 7
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
Entities connected to both Net Profit and Net Loss and the Offered Interests
Accounting Period
ORGANIZATIONReliance
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONNet Profit
ORGANIZATIONLeon Black
PERSONthe Person or Persons
ORGANIZATIONthe Offer Price
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONOccasioning Dissolution
LOCATIONAllocation of Profits
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONPurchase
LOCATIONCertificate of Formation
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATION
Wilmington
LOCATIONEach Partner's
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION