Member Minimum Gain. With respect to each Member Nonrecourse Liability, the amount of gain (of whatever character) that would be realized by the Company if it disposed of the property subject to such liability in a taxable transaction in full satisfaction of such liability (and for no other consideration). Member Minimum Gain shall be determined in a manner consistent with the rules of Treas. Reg. §1.704-2(i)(3).
Appears in 2 contracts
Sources: Operating Agreement (Comstock Holding Companies, Inc.), Operating Agreement (Comstock Holding Companies, Inc.)