Common use of Minimum Gain Chargeback Clause in Contracts

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V, if there is a net decrease in Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2). This Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Notwithstanding the provisions of Section 1.704-2(f), notwithstanding any other provision 5.1 of this Article Vthe Agreement, if there is a net decrease in Partnership Minimum Gain during any Allocation Partnership Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year year (and, if necessary, subsequent Allocation Yearsyears) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, as determined in accordance with under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Section 1.704-2(f)(6) and 1.704-2(g)(2). This Section 5.3(a5.1(c)(i) is intended to comply with the minimum gain chargeback requirement requirements in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VVII of the Partnership Agreement, if there is a net decrease in Partnership Minimum Gain during any Allocation Yeartaxable year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year taxable year (and, if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VSection 4.06, if there is a net decrease in Partnership Minimum Gain during any Allocation YearPeriod, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year Period (and, if necessary, subsequent Allocation YearsPeriods) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a4.06(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation § 1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V5, if there is a net decrease in Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2). This Section 5.3(a5.03(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VSection 3, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V5, if there is a net decrease in Partnership Minimum Gain during any Allocation YearPartnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year taxable year (and, if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section Subsection 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V5, if there is a net decrease in Partnership Minimum Gain during any Allocation YearPartnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year taxable year (and, if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section section 1.704-2(f), notwithstanding any other provision ) of this Article Vthe Regulations, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections sections 1.704-2(f)(6) and 1.704-2(g)(2)) of the Regulations. This Section 5.3(a6.3(c) is intended to comply with the minimum gain chargeback requirement in Regulations Section section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article V3, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Section 1.704-2(f)(6) and Section 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a3.2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VIV, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous immediately preceding sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a4.03(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding the provisions of Section 6.2, or any other provision of this Article V6, if there is a net decrease in Partnership Minimum Gain during any Allocation Yearfiscal year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year year (and, if necessary, subsequent Allocation Yearsyears) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined in accordance with under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a6.3.A(i) is intended to comply with the qualify as a "minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.chargeback" within the meaning of Regulation

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01 (c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VSection 3, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VSection 12, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, Gain as determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation § 1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation § 1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704Regulation §1,704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VSection 3, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s Partner ‘s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V4, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, and if necessary, necessary subsequent Allocation Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(21.704- 2(j)(2). This Section 5.3(a) 4.4.1 is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith. [*] designates portions of this document that have been omitted pursuant to a request for confidential treatment filed separately with the Commission.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation § 1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VVII of the Partnership Agreement, if there is a net decrease in Partnership Minimum Gain during any Allocation Yeartaxable year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year taxable year (and, if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)1.704- 2(j)(2) of the Regulations. This Section 5.3(a2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation § 1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership Table of Contents for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation § 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VVI, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a) 6.03.A. is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VSection 12, if there is a BHC OF INDIANA, GENERAL PARTNERSHIP - 7 - net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such the Partner’s share of the net decrease in Partnership Minimum Gain, Gain as determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)2 (f) of the Regulations, notwithstanding any other provision of this Article VSection 3, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g2 (g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(62 (f) (6) and 1.704-2(g)(2)2(j) (2) of the Regulations. This Section 5.3(a3.3 (a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f2 (f) of the Regulations and shall be interpreted consistently therewith.. (b)

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VSection 12, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such the Partner’s 's share of the net decrease in Partnership Minimum Gain, Gain as determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)1.704–2(f) of the Regulations, notwithstanding any other provision of this Exhibit C or of Article V, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g1.704–2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(61.704–2(f)(6) and 1.704-2(g)(2)1.704–2(j)(2) of the Regulations. This Section 5.3(aC.3(a) is intended to comply with the minimum gain chargeback requirement in Section 1.704–2(f) of the Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article V, if there is a net decrease in Partnership Minimum Gain during any Allocation YearPartnership taxable year, each Partner shall be specially allocated items of Partnership gross income and gain for such Allocation Year taxable year (and, and if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a5.2(a) is intended to comply with the minimum gain chargeback requirement (set forth in Regulations Section section 1.704-2(f) of the Regulations) relating to Partnership nonrecourse liabilities (as defined in section 1.704-2(b)(3) of the Regulations) and shall be interpreted consistently therewithso interpreted.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision ) of this Article Vthe Regulations, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VSection 6.1, if there is a net decrease in Partnership Minimum Gain during any Allocation YearAdjustment Period, each Partner shall be specially allocated items of Partnership gross income and gain for such Allocation Year period (and, if necessary, subsequent Allocation Yearsperiods) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Section 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a6.1(c)(ii) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VSection 5.02, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a5.02(b)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)2(0, notwithstanding any other provision of this Article VIII, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V, if there is a net decrease in Partnership Minimum Gain during any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The , and the items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a5.1(b)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Regulation Section 1.704-1.704- 2(f), notwithstanding any other provision provisions of this Article V4, if there is a net decrease in Partnership Minimum Gain during for any Allocation Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year year (and, if necessary, subsequent Allocation Yearsyears) in an amount equal to the such Partner’s 's share of the net decrease in Partnership Minimum Gain, as determined in accordance with Regulations under Regulation Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Regulation Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a) 4.3.1 is intended to comply with the minimum gain chargeback requirement in such sections of the Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1,704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(i)(2). This Section 5.3(a4.0.1(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VVI, if there is a net decrease in Partnership Minimum Gain during any Allocation Yearyear, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year year (and, if necessary, subsequent Allocation Yearsyears) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a6.6(a) is intended to comply with the minimum gain chargeback requirement in Section 1.7042(f) of the Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VVI, if there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a6.03(A) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article VARTICLE 5, if there is a net decrease in Partnership Minimum Gain during any Allocation YearPartnership taxable year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year taxable year (and, if necessary, subsequent Allocation Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section Subsection 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation § 1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article VSection 6, if there is a net decrease in Partnership Minimum Gain during any Allocation Partnership Fiscal Year, each General Partner and Limited Partner shall be specially allocated items of Partnership income and gain for such Allocation Fiscal Year (and, if necessary, subsequent Allocation Fiscal Years) in an amount equal to such Partner’s Person's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each General Partner and Limited Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a6.03(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section Regulation §1.704-2(f), notwithstanding any other provision of this Article VSection, if there is a net decrease in Minimum Gain minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in Minimum Gainminimum gain, determined in accordance with Regulations Section Regulation § 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections Regulation §1.704-2(f)(6) and Regulation §1.704-2(g)(22(j)(2). This Section 5.3(a4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulations Section Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article V0, if there is a net decrease in Partnership Minimum Gain during any Allocation Yearfiscal year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year fiscal year (and, if necessary, subsequent Allocation Yearsfiscal years) in an amount equal to such Partner’s 's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)2(j)(2) of the Regulations. This Section 5.3(a) 0 is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this Article V, if there is a net decrease in Minimum Gain Partnership minimum gain during any Allocation YearPartnership fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year fiscal year (and, if necessary, subsequent Allocation Yearsfiscal years) in an amount equal to such Partner’s share of the net decrease in Minimum GainPartnership minimum gain, determined in accordance with Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(2)1(j)(2) of the Regulations. This Section 5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulations Section 1.704-2(f1(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulations Section 1.704-2(f), notwithstanding any other provision of this Article V, if If there is a net decrease in Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain for such Allocation Year (and, if necessary, subsequent Allocation Years) in proportion to, and to the extent of, an amount equal to such Partner’s share of the net decrease in Partnership Minimum Gain, Gain determined in accordance with Treasury Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be so allocated to each Partner pursuant thereto. The items to be so allocated shall will be determined in accordance with Treasury Regulations Sections 1.704-2(f)(6) and 1.704-2(g)(22(j)(2). This Section 5.3(a6.2(a) is intended to comply with the minimum gain chargeback requirement in Treasury Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.