ins (including short-ter► capital gains) for Federal income tax purposes ("gains") for any fiscal year during or as of the end of which one or more Positive Basis Partners withdraw from the Partnership pursuant to Articles V or VII, the General Partner may elect to allocate such gains as follows: (i) to allocate such g

gains (including short-term capital gains) or capital losses for federal income tax purposes for any Fiscal Year as of the end of which one or more Positive Basis Partners (as hereinafter defined) or Negative Basis Partners (as hereinafter defined) withdraw from the Partnership pursuant to Articles IV, V or VII, the Ge