Common use of Partnership Minimum Gain Clause in Contracts

Partnership Minimum Gain. Notwithstanding any other provisions of this Agreement, in the event there is a net decrease in Partnership Minimum Gain during a fiscal year, the Partners shall be allocated items of income and gain in accordance with Treasury Regulations Section 1.704-2(f). For purposes of this Agreement, the term “Partnership Minimum Gain” shall mean “Partnership Minimum Gain” as set forth in Treasury Regulations Section 1.704-2(b)(2), and any Partner’s share of Partnership Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(l). This Section 3.2(e)(i) is intended to comply with the minimum gain charge-back requirement of Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent therewith.

Partnership Minimum Gain. Notwithstanding any other provisions of this AgreementExcept as otherwise provided in ------------------------ Treasury Regulations Section 1.704-2(f), in the event if there is a net decrease in Partnership Minimum Gain during a fiscal yearany Partnership Fiscal Year, the Partners each Partner shall be specially allocated items of Partnership income and gain for such period (and, if necessary, subsequent periods) in accordance with Treasury Regulations Section 1.704-2(f). For purposes proportion to, and to the extent of, an amount equal to the portion of this Agreement, such Partner's share of the term “net decrease in Partnership Minimum Gain” shall mean “Partnership Minimum Gain” as set forth in Treasury Regulations Section 1.704-2(b)(2), and any Partner’s share of Partnership Minimum Gain shall be determined in accordance with Treasury Regulations Section 1.704-2(g)(l2(g). This Section 3.2(e)(i) 3.3 is intended to comply with the minimum chargeback of items of income and gain charge-back requirement of in Treasury Regulations Section 1.704-2(f) and shall be interpreted and applied in a manner consistent consistently therewith.