n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284035 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of

n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284052 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of

f Company income and gain (including gross income) shall be specially allocated to such Member to the extent required and in the manner specified by Treasury Regulations Sections 1.704-1(b)(2)(ii)(d) in an amount and manner sufficient to eliminate the such deficit balance as quickly as possible. This provision is intended to

ar (and, if necessary, subsequent years) in an amount equal to its respective share of such net decrease during such year, determined pursuant to Treasury Regulations Sections 1.704- 2(g) and 1.704-2(i)(5). The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.7042(f). This S