Common use of Allocations for Income Tax Purposes Clause in Contracts

Allocations for Income Tax Purposes. (a) Except as otherwise required by Code Section 704(c), items of income, gain, deduction, loss, or credit that are recognized for income tax purposes in each Fiscal Year shall be allocated among the Participants, in such manner as to reflect equitably amounts credited to or debited against each Participant’s Capital Account, whether in such Fiscal Year or in prior Fiscal Years. To this end, DME shall establish and maintain records that show the extent to which the Capital Account of each Participant, as of the last day of each Fiscal Year, consists of amounts that have not been reflected in the taxable income of such Participant. To the extent deemed by DME, in its reasonable discretion, to be feasible and equitable, taxable income and gains in each Fiscal Year shall be allocated among the Participants who have enjoyed the related credits to their Capital Accounts, and items of deduction, loss and credit in each Fiscal Year shall be allocated among the Participants who have borne the burden of the related debits to their Capital Accounts.

Allocations for Income Tax Purposes. (a) Except as otherwise required by Code Section section 704(c)) of the Code, items of income, gain, deduction, loss, or credit that are recognized for income tax purposes in each Fiscal Year shall be allocated among the Participants, Partners in such manner as to reflect equitably amounts credited to or debited against each ParticipantPartner’s Capital Account, whether in such Fiscal Year or in prior Fiscal Years. To this end, DME the Partnership shall establish and maintain records that shall show the extent to which the Capital Account of each ParticipantPartner, as of the last day of each Fiscal Year, consists of includes amounts that have not been reflected in the taxable income of such ParticipantPartner. To the extent deemed feasible and equitable (as determined by DME, the General Partner in its reasonable sole discretion, to be feasible and equitable), taxable income and gains in each Fiscal Year shall be allocated among the Participants Partners who have enjoyed the related credits to their Capital Accounts, and items of deduction, loss and credit in each Fiscal Year shall be allocated among the Participants Partners who have borne the burden of the related debits to their Capital Accounts.