Section 704 Allocations Sample Clauses

Section 704 Allocations. In the event that the fair market value of an item of Company property differs from its tax basis, allocations of depreciation and amortization, gain and loss with respect to such property will be made for tax purposes in a manner that takes account of the variation between the tax basis and the fair market value of such property in accordance with the Internal Revenue Code Section 704 and Treasury Regulations Section 1.704-1(4).

Section 704 Allocations. Any special allocations necessary to comply with the requirements set forth in Section 704 of the Code and the

Section 704 Allocations. Notwithstanding any other provision of this Operating Agreement, to the extent an allocation of income, gain, profit, loss, deduction or credit or any item thereof, as set forth in this Article VII, to any Member would be in violation of the requirements of Treasury Regulation Section 1.704-1(b), the Tax Matters Partner shall comply with the requirements of such Treasury Regulations and amend such allocations to comply with such requirements in a manner that will, in the reasonable judgment of the Tax Matters Partner, have the least effect on any amounts to be distributed hereunder. Notwithstanding anything herein to the contrary, this Operating Agreement shall not be construed as creating a deficit restoration obligation or otherwise personally obligating any Member to make any capital contributions except as required by Article IV.