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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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
Entities connected to both Net Profit and Net Loss and the Withdrawing Partner's Partnership Interest
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
ORGANIZATIONPurchase
LOCATIONthe Offered Interests
ORGANIZATIONEach Partner's
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATION