and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 3 contracts
Sources: Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 3 contracts
Sources: Limited Partnership Agreement (CBL/Regency I, LLC), Agreement of Limited Partnership (CBL/Regency I, LLC), Limited Partnership Agreement (CBL/Regency I, LLC)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Managing Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 2 contracts
Sources: Partnership Agreement (CBL/Regency I, LLC), Partnership Agreement (CBL/Regency I, LLC)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (fl(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(il(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(il(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner- ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
Sources: Limited Partnership Agreement (CBL & Associates Limited Partnership)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) 1 (2) (iv) (fb)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i1 (b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i1.704- 1 (c)(2)(i) and the General Managing Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.The
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b)paragraph (b) hereof, Tax Items with respect to Partnership property that are is subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i)3, as the case may be. The allocation of Tax Items shall be subject to the “ceiling ruletraditional method with curative allocations,” stated as set forth in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule3(c).
Appears in 1 contract
Sources: Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section -Section 704(c) Tax Items”Items-) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” -ceiling rule- stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner-ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner-ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(il(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(il(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
Sources: Agreement of Limited Partnership (CBL & Associates Limited Partnership)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner- ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704l.704-1(bl(b) (2) (iv) (f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i1 (c) (2) (i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
Sources: Limited Partnership Agreement (CBL & Associates Limited Partnership)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), . Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i1 (b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(il(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner-ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(il(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(il(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
Sources: Agreement of Limited Partnership (CBL/Regency I, LLC)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Not with standing Section 4.4(b4.4 (b), Tax Items with respect to Partnership property that are subject to Code Section 704(c704 (c) and/or Regulation Section 1.704-1(b1 (b) (2) (iv) (f) (collectively “Section 704(c704 (c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i1 (b) (4) (i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i1 (c) (2) (i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
Sources: Limited Partnership Agreement (CBL & Associates Limited Partnership)
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership Partner ship property that are subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (fl(b)(2)(iv)(f) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(il(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” stated in Regulation Section 1.704-1(c)(2)(i) and the General Partner will not make special, curative or other allocations to compensate for or cure the effect of such ceiling rule.
Appears in 1 contract
and Revaluations; Curative Allocations Resulting from the Ceiling Rule. Notwithstanding Section 4.4(b)paragraph (b) hereof, Tax Items with respect to Partnership property that are is subject to Code Section 704(c) and/or Regulation Section 1.704-1(b) (2) (iv) (f1(b)(2)(iv)(1) (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-1(b)(4)(i), as the case may be. The allocation of Tax Items shall be subject to the “ceiling rule” rule stated in Regulation Section 1.704-1(c)(2)(i) and the ). The General Partner will not make special, curative or is authorized to specially allocate Tax Items (other allocations than the Section 704(c) Tax Items) to compensate cure for or cure the effect of such the ceiling rule.
Appears in 1 contract
Sources: Limited Partnership Agreement (HTS-Sunset Harbor Partner, L.L.C.)