Prohibition Against Publicly Traded Partnership. The Manager shall take all action necessary to prevent the Company from qualifying as a publicly traded partnership within the meaning of Code Section 7704, including, without limitation, limiting the number of Members to less than 500 in compliance with the safe harbor under IRS Notice 88-75.
Appears in 6 contracts
Samples: Assignment of Interest (Wellsford Real Properties Inc), Operating Agreement (Wellsford Real Properties Inc), Pledge and Security Agreement (Wellsford Residential Property Trust)