Common use of ESTABLISHMENT AND MAINTENANCE OF CAPITAL ACCOUNTS; PARTNERSHIP STATUS Clause in Contracts

ESTABLISHMENT AND MAINTENANCE OF CAPITAL ACCOUNTS; PARTNERSHIP STATUS. The General Partner shall establish and cause the Partnership to maintain a single Capital Account for each Partner which reflects such Partner's Capital Contributions to the Partnership. Each Partner's Capital Account shall also reflect the allocations and distributions made to such Partner pursuant to Articles 3 and 4 and otherwise be adjusted in accordance with Code Section 704 and the principles set forth in Regulations Sections 1.704-1(b) and 1.704-2. In applying such principles, any expenditures of the Partnership described in Code Section 705(a)(2)(B) or treated as Code Section 705(a)(2)(B) expenditures pursuant to Regulations Section 1.704-1(b)(2)(iv)(i) shall be allocated among the Partners in proportion to their respective Funding Proportions. The Partners intend that the Partnership be treated as a partnership for tax purposes.

ESTABLISHMENT AND MAINTENANCE OF CAPITAL ACCOUNTS; PARTNERSHIP STATUS. The General Partner shall establish and cause the Partnership to maintain a single Capital Account for each Partner which reflects such Partner's Capital Contributions to the Partnership. Each Partner's Capital Account shall also reflect the allocations and distributions made to such Partner pursuant to Articles 3 and 4 and otherwise be adjusted in accordance with Code Section 704 and the principles set forth in Regulations Sections 1.704-1(b) and 1.704-2. In applying such principles, any expenditures of the Partnership described in Code Section 705(a)(2)(B) or treated as Code Section 705(a)(2)(B705(a)(2)(E) expenditures pursuant to Regulations Section 1.704-1(b)(2)(iv)(i) shall be allocated among the Partners in proportion to their respective Funding Proportions. The Partners intend that the Partnership be treated as a partnership for tax purposes.