Common use of Allocation of Gain or Loss Upon Sale Clause in Contracts

Allocation of Gain or Loss Upon Sale. Notwithstanding Section 5.3(b) and Section 5.3(c), and after giving effect to the allocations provided in Section 5.3(a), in the event of a sale, exchange, or other disposition of all or substantially all of the assets of the Partnership, or upon the liquidation of the Partnership within the meaning of Treasury Regulations Section 1.704-1(b)(2)(ii)(g), beginning in the year in which the contract or agreement for such sale is entered into or, if such contract or agreement is entered into on or prior to the date on which the Partnership's Federal income tax return with respect to the prior year is required to be filed (not including any extensions), beginning in such prior year: