is Section B-5(b) are solely for purposes of Federal and, as applicable, state and local, income tax purposes and shall not affect the allocation of Net Profits or Net Losses as between Members or any Member's Capital Account. B-6 Tar Matters Member. The Manager is hereby designated the "Tax Matters Member

is Section B-5(b) are solely for purposes of Federal and, as applicable, state and local, income tax purposes and shall not affect the allocation of Net Profits or Net Losses as between Members or any Member's Capital Account. B-6 Tar Matters Member. The Manager is hereby designated the "Tax Matters Member

. 3.9 Priority and Return of Capital. No Member shall have priority over any other Member, whether for the return of a Capital Contribution or for Net Profits, Net Losses, or a Distribution• provided, that this Section 3.9 shall not apply to loans or other indebtedness (as distinguished from a Capital Con