Modifications of Imputed Underpayments. Other than as is otherwise expressly stated in this Agreement, the Manager may make any request for modifications of an “imputed underpayment” to the IRS, or cause the Partnership Representative or other Person to make any such request for any such modification, under the Internal Revenue Code as the Manager deems to be in the best interests of the Company, even if such an election has a negative effect on the Capital Account of one or more current or former Members.
Appears in 6 contracts
Samples: Operating Agreement (Central Park Fund 1, LLC), Operating Agreement (Central Park Fund I, LLC), Operating Agreement (Aurora Fund I, LLC)
