Allocation Election. The Company shall be required to elect to allocate the items described in Section 1362(e)(2)(A) of the Code pursuant to Section 1362(e)(3) of the Code under "normal tax accounting rules," and the Stockholders agree to consent to such election and to provide the Company with the statement of consent of all Stockholders described in Section 1.1362-6(a)(5) and Section 1.1362-6(b) of the Treasury Regulations.
Allocation Election. Tax items shall be allocated to the S Short Year and the C Short Year pursuant to normal tax accounting rules (that is, the "closing of the books method") rather than by the pro rata allocation method contained in Section 1362(e)(2) of the Code.
Allocation Election. The Company shall elect to allocate tax items ------------------- to its S Short Year and C Short Year pursuant to the normal tax accounting method (rather than the pro rata allocation method) contained in Section 1362(e)(3) of the Code.
Allocation Election. 2 ARTICLE III - TAXES........................................................ 2
Allocation Election. Corporation shall terminate its S corporation status by a revocation of such status pursuant to section 1361(d)(1) of the Code by filing the form attached hereto and marked "Exhibit A." The Shareholders shall consent to the revocation of the S corporation election by filing the form, attached hereto and marked "Exhibit B"no later than one day before the closing of the Offering (the "Termination Date"). Further, Corporation shall elect to allocate items between its two taxable years ending and beginning, respectively, on the date of termination and the date after the termination of the S election, "under normal tax accounting rules," that is, the "closing of the books method," as provided in section 1362(e)(3)(A) of the Code by filing the form attached hereto as "Exhibit C." The Shareholders shall each consent to the "closing of the books method" election, by filing the forms attached hereto and marked "Exhibit D" pursuant to section 1362(e)(3)(B)of the Code.
Allocation Election. The Company will elect to allocate the items described in section 1362(e)(2)(A) of the Code pursuant to section 1362(e)(3) of the Code under "normal tax accounting rules," and the Stockholder will consent to such election and will provide the Company with the statement of consent described in section 1.1362-6(b) of the Treasury Regulations.
Allocation Election. The Company intends to allocate tax items to its S Short Year and C Short Year pursuant to the method contained in Section 1362(e) (3) of the Code, but may allocate pursuant to any other permitted method under Section 1362(e) of the Code.
Allocation Election. Parent will elect to file a consolidated federal income tax return with CHCI for the taxable year beginning on the Termination Date in accordance with Treas. Reg. Section 1.1502-75(a) and the Company shall consent to such election as required by Treas. Reg. Section 1.1502-75(b). ARTICLE III OBLIGATIONS
Allocation Election. The Company agrees to elect and the Shareholders agree to consent, pursuant to Section 1362(e)(3) of the Code, to allocate tax items to its S Short Year and C Short Year by the pro rata allocation method contained in Section 1362(e)(2) of the Code, rather then pursuant to normal tax accounting rules (the "closing of the books method"). The Company and the Shareholders agree to take all necessary actions to cause such election and consents and the revocation election and consents to be effective for federal income tax purposes, prior to the Termination Date. Additionally, the Company agrees to execute and attach to its tax return filed with the Internal Revenue Service an executed election.
Allocation Election. The Company intends to allocate tax items to its S Short Year and C Short Year using normal accounting rules pursuant to the election method contained in Section 1362(e)(3) of the Code, and the Stockholders covenant and agree to consent to such election method.
