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minimis nature. 14.8 General Provisions. (a) Power of Attorney. Each of the undersigned by executio
d to restore to the Partnership within the meaning of Treasury Regulation Section 1.704- 1(b)(2)(iiXc) or is deemed obligated to restore pursuant to Treasury Regulation Sections EFTA00806034 CONFIDENTIAL 1.704-2(g) and 1.704-2(i)(5) and decreasing it by the amounts specified in Treasury Regulation Sections 1.704-1(b)(2)(
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the Members or the Company. (g) Limitations on Power of Members. Except as expressly authorized by thi
uch allocation, minus (ii) such Member's or Assignee's share of Company minimum gain and Member nonrecourse debt minimum gain determined pursuant to Treasury Regulation Sections 1.704-2(gX1) and 1.704-2(iX5), computed immediately prior to the hypothetical sale of assets. Adjustments shall be made in the allocations of profi
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f Partnership Agreement 21 Section 8.2 Special Power-of-Attorney 22 Section 8.3 Notices 23 Sectio
ursuant to an In- Kind Exchange Distribution shall be treated as a distribution of an undivided interest in the Partnership's assets as described in Treasury Regulation Sections 1.704-4(cX6) and 1.737-2(dX4). (b) If any Partner or Partners are treated for United States federal income tax purposes as realizing ordinary inco
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