Common use of Partner Nonrecourse Deductions Clause in Contracts

Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for the taxable period shall be allocated 100% to the Partner that bears the Economic Risk of Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, such Partner Nonrecourse Deductions attributable thereto shall be allocated among such Partners in accordance with the manner in which they share such Economic Risk of Loss. The allocations in this portion of Section 6.1(d) are a Required Allocation for purposes of the allocation of Curative Allocations in Section 6.1(d).

Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for the any taxable period shall be allocated 100% to the Partner that bears the Economic Risk of Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, such Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the manner ratios in which they share such Economic Risk of Loss. The allocations in this portion of This Section 6.1(d6.1(b)(vii) are a Required Allocation for purposes of the allocation of Curative Allocations in is intended to comply with Treasury Regulations Section 6.1(d)1.704-2(i)(1) and shall be interpreted consistently therewith.

Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for the any taxable period shall be allocated 100% to the Partner that bears the Economic Risk of Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, such Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the manner ratios in which they share such Economic Risk of Loss. The allocations in this portion of This Section 6.1(d6.1(d)(vii) are a Required Allocation for purposes of the allocation of Curative Allocations in is intended to comply with Treasury Regulations Section 6.1(d)1.704-2(i)(1) and shall be interpreted consistently therewith.

Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for the any taxable period shall be allocated 100% to the Partner that bears the Economic Risk of Loss with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulation Section 1.704-2(i). If more than one Partner bears the Economic Risk of Loss with respect to a Partner Nonrecourse Debt, such Partner Nonrecourse Deductions attributable thereto shall be allocated between or among such Partners in accordance with the manner ratios in which they share such Economic Risk of Loss. The allocations in this portion of This Section 6.1(d6.1(c)(vii) are a Required Allocation for purposes of the allocation of Curative Allocations in is intended to comply with Treasury Regulations Section 6.1(d)1.704-2(i)(1) and shall be interpreted consistently therewith.