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).

Appears in 8 contracts

Sources: Limited Partnership Agreement (American Materials Transport, Inc.), Limited Partnership Agreement (AmREIT Monthly Income & Growth Fund IV LP), Limited Partnership Agreement (AmREIT Monthly Income & Growth Fund IV LP)

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.

Appears in 5 contracts

Sources: Letter Agreement (Bioceres S.A.), Letter Agreement (Bioceres S.A.), Letter Agreement (Bioceres S.A.)

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership 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 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.

Appears in 4 contracts

Sources: Limited Partnership Agreement (Bumble Bee Capital Corp.), Limited Partnership Agreement (Bumble Bee Capital Corp.), Limited Partnership Agreement (Bumble Bee Capital Corp.)

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).

Appears in 4 contracts

Sources: Limited Partnership Agreement (Cornell Corrections of Rhode Island, Inc.), Limited Partnership Agreement (Cornell Corrections of Rhode Island, Inc.), Limited Partnership Agreement (Golfsmith International Holdings Inc)

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).

Appears in 3 contracts

Sources: Limited Liability Company Agreement (DCT Chino LLC), Limited Liability Company Agreement (Glimcher Realty Trust), Purchase and Sale Agreement (Glimcher Realty Trust)

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).

Appears in 3 contracts

Sources: Operating Agreement (Jack Miller Family Limited Partnership 1), Operating Agreement (Tekoil & Gas Corp), Operating Agreement (General Automotive Co)

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).

Appears in 3 contracts

Sources: Limited Partnership Agreement (Cedar Income Fund LTD /Md/), Limited Partnership Agreement (Cedar Income Fund LTD /Md/), Limited Partnership Agreement (Cedar Income Fund LTD /Md/)

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.

Appears in 3 contracts

Sources: Limited Liability Company Agreement (Grom Social Enterprises, Inc.), Operating Agreement (MVP REIT II, Inc.), Operating Agreement (Emmis Communications Corp)

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).

Appears in 2 contracts

Sources: Limited Liability Company Agreement (Apartment Investment & Management Co), Limited Liability Company Agreement (Storage Usa Inc)

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).

Appears in 2 contracts

Sources: Limited Partnership Agreement (Fiber Glass Systems Lp), Limited Partnership Agreement (Fiber Glass Systems Lp)

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).

Appears in 2 contracts

Sources: Limited Liability Company Agreement (DCT Chino LLC), Limited Liability Company Agreement (DCT Chino LLC)

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).

Appears in 2 contracts

Sources: Limited Liability Company Agreement (Grubb & Ellis Healthcare REIT II, Inc.), Limited Liability Company Agreement (Grubb & Ellis Healthcare REIT, Inc.)

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership 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 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 basis), and the 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 pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m).;

Appears in 2 contracts

Sources: Limited Partnership Agreement (Kaneb Pipe Line Partners L P), Limited Partnership Agreement (Kaneb Pipe Line Partners L P)

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset 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 assetAsset) 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).

Appears in 1 contract

Sources: Limited Partnership Agreement (Select Water Solutions, Inc.)

Code Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership 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)(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 and Assignees 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).

Appears in 1 contract

Sources: Limited Partnership Agreement (Kimco Realty Corp)

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).

Appears in 1 contract

Sources: Limited Partnership Agreement (AmREIT Monthly Income & Growth Fund III LTD)

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).

Appears in 1 contract

Sources: Limited Liability Company Agreement (Cb Richard Ellis Realty Trust)

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).

Appears in 1 contract

Sources: Partnership Interest Purchase Agreement (CNL Income Properties Inc)

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).

Appears in 1 contract

Sources: Limited Partnership Agreement (American Materials Transport, Inc.)

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).

Appears in 1 contract

Sources: Limited Partnership Agreement (CNL Income Properties Inc)

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 under Section 1.7041. 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).

Appears in 1 contract

Sources: Limited Partnership Agreement (Txi Transportation Co)

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.

Appears in 1 contract

Sources: Limited Partnership Agreement (Metropolitan Capital Advisors Inc)

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).

Appears in 1 contract

Sources: Limited Liability Company Agreement (DCT Chino LLC)

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.

Appears in 1 contract

Sources: Operating Agreement

Code Section 754 Adjustments. 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).

Appears in 1 contract

Sources: Limited Liability Company Agreement

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).

Appears in 1 contract

Sources: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.)

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).

Appears in 1 contract

Sources: Limited Liability Company Agreement (Storage Usa Inc)

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 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 Unitholders 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.

Appears in 1 contract

Sources: Limited Liability Company Agreement (Usana Health Sciences Inc)

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).

Appears in 1 contract

Sources: Limited Partnership Agreement (CNL Income Mesa Del Sol, LLC)

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 1.7041. 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).

Appears in 1 contract

Sources: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.)

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).

Appears in 1 contract

Sources: Limited Liability Company Agreement (Lightstone Real Estate Income Trust Inc.)

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).

Appears in 1 contract

Sources: Partnership Agreement (Cedar Income Fund LTD /Md/)

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).

Appears in 1 contract

Sources: Limited Partnership Agreement (Us Home & Garden Trust I)