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) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
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
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
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
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
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 the Partnership for Federal and the Revised Limited Partnership Act
Withdrawing Partner
PERSON
Wilmington
LOCATIONReliance
ORGANIZATIONPurchase
LOCATIONElysium Management LLC
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONClass A General Partnership Interests
ORGANIZATIONClass of Partnership Interests
ORGANIZATIONOccasioning Dissolution
LOCATIONLeon Black
PERSONAccounting Period
ORGANIZATIONCorporation Services Company
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONFirst Refusal
ORGANIZATIONNet Profit
ORGANIZATIONEach Partner's
ORGANIZATION