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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
this Section 8.4.2, the successor General Partner may not be related or subordinate to LDB within the meaning of Section 672(c) of the Code. 8.4.3 The General Partnership Interests of a General Partner who resigns or is removed pursuant to the foregoing provisions of this Section 8.4 automatically shall be converted into Limited Partnership Intere
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
this Section 8.4.2, the successor General Partner may not be related or subordinate to LDB within the meaning of Section 672(c) of the Code. 8.4.3 The General Partnership Interests of a General Partner who resigns or is removed pursuant to the foregoing provisions of this Section 8.4 automatically shall be converted into Limited Partnership Intere
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
this Section 8.4.2, the successor General Partner may not be related or subordinate to LDB within the meaning of Section 672(c) of the Code. 8.4.3 The General Partnership Interests of a General Partner who resigns or is removed pursuant to the foregoing provisions of this Section 8.4 automatically shall be converted into Limited Partnership Intere
Entities connected to both the Offered Interests and The General Partnership Interests of a General Partner
Reliance
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAccounting Period
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONLeon Black
PERSONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONPurchase
LOCATIONAllocation of Profits
ORGANIZATIONNet Profit
ORGANIZATIONNet Profit and Net Loss
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONCertificate of Formation
ORGANIZATIONLimited Partner's Partnership Interests
ORGANIZATIONWithdrawing Partner
PERSON
Wilmington
LOCATIONElysium Management LLC
ORGANIZATION