Section 704(c) Method. LVP and POAC shall use, and each of LVP and POAC shall cause any other entity in which it has a direct or indirect interest to use, the “traditional method” under Treasury Regulation Section 1.704-3(b) without curative allocations for purposes of making allocations under Section 704(c) of the Code or reverse Section 704(c) allocations with respect to the Contributed Interest and the Properties to take into account the book-tax disparities as of the date hereof with respect to the Contributed Interest and the Properties.
Appears in 2 contracts
Sources: Tax Protection Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.), Tax Protection Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.)