Common use of Section 704(c) Clause in Contracts

Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of the Partnership shall, solely for U.S. federal income tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of such property to the Partnership for U.S. federal income tax purposes and its initial Carrying Value (computed in accordance with the definition of Carrying Value) using such method(s) and convention(s) as may be permitted under Regulations Section 1.704-3, as determined by the General Partner in its discretion. In the event the Carrying Value of any Partnership asset is adjusted in accordance with the definition of Carrying Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for U.S. federal income tax purposes and its Carrying Value using such method(s) and convention(s) as may be permitted under Regulations Section 1.704-3, as determined by the General Partner in its discretion.