Common use of Purpose and Application Clause in Contracts

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Appendix are to comply with the provisions of Regulations Sections 1.704-1(b) and 1.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Board, in allocating items of income, gain, loss, or deduction among the Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Board shall apply the provisions of this Section in whatever order the Board reasonably believes will minimize the effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement Sections 9.1(c), (d), and Sections 1.2(a) through (g) of this Appendix are to comply with the provisions of Regulations Sections sections 1.704-1(bl(b) and 1.704-22 of the Income Tax Regulations, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Board, Members in allocating items of income, gain, loss, or deduction among the Members, Members shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member’s 's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Board Members shall apply the provisions of this Section 9.1 in whatever order the Board they reasonably believes believe will minimize any economic distortion that otherwise might result from the effect application of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Appendix are to comply with the provisions of Regulations Sections 1.704l.704-1(b) and 1.704l.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Board, in allocating items of income, gain, loss, or deduction among the Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Board shall apply the provisions of this Section in whatever order the Board reasonably believes will minimize the effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Appendix are to comply with the provisions of Regulations Sections 1.704-1(b) and 1.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the BoardManagers, in allocating items of income, gain, loss, or deduction among the Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member’s 's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Board Managers shall apply the provisions of this Section in whatever order the Board Managers reasonably believes believe will minimize the effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Appendix are to comply with the provisions of Regulations Sections 1.704-1(b) and 1.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Management Board, in allocating items of income, gain, loss, or deduction among the Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Management Board shall apply the provisions of this Section in whatever order the Management Board reasonably believes will minimize the effect of the special allocations.