Allocation of Net Income and Net Loss. After giving effect to the special allocations in Section 8.3, all Net Income and Net Loss of the Partnership, and all items of taxable income, expense, and deduction entering into the determination of such Net Income and Net Loss shall be allocated to the General Partner and to the Limited Partner in accordance with their respective Partnership Percentage. No allocation of Net Loss will be made to a Partner that would create an impermissible Capital Account balance for that Partner as computed under Treasury Regulations Section 1.704-1(b)(2)(ii)(d).
Appears in 6 contracts
Samples: Agreement (Marietta Surgical Center, Inc.), Agreement (Marietta Surgical Center, Inc.), Agreement (Marietta Surgical Center, Inc.)
Allocation of Net Income and Net Loss. After giving effect to the special allocations in Section 8.3, all Net Income and Net Loss of the Partnership, and all items of taxable income, expense, and deduction entering into the determination of such Net Income and Net Loss shall be allocated to the General Partner and to the Limited Partner in accordance with their respective Partnership Percentage. No allocation of Net Loss will be made to a Partner that would create an impermissible Capital Account balance for that Partner as computed under Treasury Regulations Section 1.704-1(b)(2)(ii)(d1.704.1(b)(2)(ii)(d).
Appears in 1 contract
Samples: Marietta Surgical Center, Inc.