Common use of Code Section 754 Adjustments Clause in Contracts

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations. [THE REMAINDER OF THIS PAGE INTENTIONALLY HAS BEEN LEFT BLANK.]

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections 734(b) or 743(b) is required pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under pursuant to Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), . the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent that an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Regulations § 1.704-l(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts capital accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts capital accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts capital accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership LLC asset under pursuant to Code Sections § 734(b) or Code § 743(b) is required required, pursuant to Treasury Regulations § 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required required, pursuant to Treasury Regulation section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Treasury Regulation.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b743(c) of the Code is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required required, pursuant to Regulation section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to the Regulations to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Regulation Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Regulation Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections Company Asset pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Fund asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the ---------------------------- adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required required, pursuant to Treasury Regulation section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Treasury Regulations Section 1.704-1 (b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2) (iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basisbasis of the asset), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Section 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) ), or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership LLC asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the ---------------------------- adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b743(c) of the Code is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Regulation Section l.704-l(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2(iv)(wy).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required pursuant to the Allocation Regulations to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to the Allocation Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to ---------------------------- the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts capital accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts capital accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts capital accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1.704- 1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections 734(b) or 743(b) is required pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be be, specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to ---------------------------- the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b743(c) of the Code is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset 41 under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Regulations Treasury Regulation Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Treasury Regulation Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m).of the Treasury Regulations. 4.3

Code Section 754 Adjustments. To the extent an ---------------------------- adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Regulations Treasury Regulation Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Treasury Regulation Section 1.704-1.704- 1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership LLC asset under Code Sections pursuant to Sec. 734(b) or 743(b) of the Code is required required, pursuant to Regulations Sec. 1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the such adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Regulations Section pursuant to Treasury Regulation section 1.704-1(b)(2)(iv)(m), the amount of the such adjustment to in the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the such asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Parties in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to the Allocation Regulations, to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to the Allocation Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required required, pursuant to Regulations section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the adjustment such adjustments to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) 743 of the Code is required required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent that an adjustment to the adjusted tax basis of any Partnership asset under Code Sections pursuant to Section 734(b) or 743(bof the Code is required, pursuant to Section 1.704- 1(b)(iv)(m) is required of the Treasury Regulations, to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the assetbasis) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such Treasury Regulations.

Code Section 754 Adjustments. To Pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner that is consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).pursuant to such Treasury Regulations. Operating Agreement

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset Company Assets under Code Sections Section 734(b) or Section 743(b) is required required, under Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or (4), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the item of gain or loss will be specially allocated to the Partners in a manner Members consistent with the manner in which how their Capital Accounts are required to must be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)that section of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b743(c) of the Code is required required, pursuant to Treasury Regulations Section 1.704 -1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Regulation Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Regulation Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to section 734(b) or 743(b) of the Code is required required, pursuant to Regulations section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the adjustment such adjustments to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Company Property pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to the Regulations to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if of the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)pursuant to such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections § 734(b) or Code §743(b) is required required, pursuant to Treasury Regulations § 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Regulation Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basisbasis of the asset), and the gain or loss will be specially allocated to the Partners Member in a manner consistent with the manner in which their its Capital Accounts are required to be adjusted under Regulations Regulation Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership LLC asset under pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset Company Property under Code Sections Section 734(b) or Code Section 743(b) is required to be taken into account in for determining Capital Accounts under Treasury Regulations Section 1.704l.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the any such adjustment to the Capital Accounts will be is treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), ) and the such gain or loss will be is specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under pursuant to Code Sections § 734(b) or Code § 743(b) is required required, pursuant to Treasury Regulation § 1.704-l(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m1.704- l(b)(2(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections Section 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1.704- 1(b)(2)(iv)(m), the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m)such section of the Regulations.

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Treasury Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Treasury Regulations Section 1.704-1(b)(2)(iv)(m1.704- l(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) of the Code is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m).

Code Section 754 Adjustments. (6) Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections 734(b) or 743(b) is required to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m), the amount of the adjustment to the Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the basis), and the gain or loss will be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations Section 1.704-1(b)(2)(iv)(m).

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset under Code Sections pursuant to Section 734(b) or 743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts under Regulations Section 1.704-1(b)(2)(iv)(m)Accounts, the amount of the such adjustment to the Capital Accounts will shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases the such basis), and the such item of gain or loss will shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted under Regulations pursuant to such Section 1.704-1(b)(2)(iv)(m)of the Treasury Regulations.