Common use of Section 754 Adjustments Clause in Contracts

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the Regulations.

Appears in 4 contracts

Sources: Limited Partnership Agreement (Jamestown Invest 1, LLC), Limited Partnership Agreement (Jamestown Invest 1, LLC), Limited Partnership Agreement (Jamestown Atlanta Invest 1, LLC)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 4 contracts

Sources: Limited Partnership Agreement (Gotham Golf Corp), Limited Partnership Agreement (Capstar Hotel Co), Limited Partnership Agreement (Gotham Golf Corp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(ml(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Treasury Regulations.

Appears in 4 contracts

Sources: Limited Partnership Agreement (Duke Realty Limited Partnership/), Limited Partnership Agreement (Duke Realty Limited Partnership/), Limited Partnership Agreement (Duke Realty Limited Partnership/)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulationsl(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 3 contracts

Sources: Agreement of Limited Partnership (Camden Property Trust), Agreement of Limited Partnership (Sl Green Realty Corp), Agreement of Limited Partnership (Sl Green Realty Corp)

Section 754 Adjustments. To the extent an adjustment to the ----------------------- adjusted tax basis of any Partnership asset pursuant to Section 734(b) of the Code or Section 743(b743(c) of the Code is required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Adjusted Capital Accounts are required to be adjusted pursuant to such section of the RegulationsTreasury Regulations Section 1.704-1(b)(2)(iv)(m).

Appears in 3 contracts

Sources: Limited Partnership Agreement (Cencom Cable Entertainment Inc /New), Limited Partnership Agreement (Cencom Cable Entertainment Inc /New), Limited Partnership Agreement (Cencom Cable Entertainment Inc /New)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(m1(b)(2)(iv) of the Regulations(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases increase the basis of the asset) asset or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the Regulationssection.

Appears in 2 contracts

Sources: Limited Partnership Agreement (Atlas Pipeline Partners Lp), Limited Partnership Agreement (Atlas Pipeline Holdings, L.P.)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 2 contracts

Sources: Limited Partnership Agreement (Advanced Prosthetics of America, Inc.), Limited Partnership Agreement (JMA Associates, Inc.)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) , and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 2 contracts

Sources: Limited Partnership Agreement (Gables Residential Trust), Limited Partnership Agreement (Gables Realty Limited Partnership)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or (including any such adjustments pursuant to Regulations Section 743(b1.734-2(b)(1)) of the Code is required, pursuant to Section Regulations Sections 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners and Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 2 contracts

Sources: Limited Partnership Agreement (OCI Resources LP), Limited Partnership Agreement (OCI Resources LP)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section under Code section 734(b) or Section Code section 743(b) of the Code is required, pursuant to Section 1.704-section 1.704- 1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such the adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basisthe tax basis of the asset) and such that gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section that Section of the Regulations.

Appears in 2 contracts

Sources: Limited Partnership Agreement, Limited Partnership Agreement

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset property pursuant to Section Sections 734(b) or Section 743(b) of the Code is required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall will be treated as an item of gain (if the adjustment increases the basis of the assetproperty) or loss (if the adjustment decreases such basisproperty) and such gain or loss shall will be specially allocated to among the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the RegulationsTreasury Regulations Section 1.704- 1(b)(2)(iv)(m).

Appears in 2 contracts

Sources: Limited Partnership Agreement (Stratus Properties Inc), Limited Partnership Agreement (Stratus Properties Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section Sections 1.704-1(b)(2)(iv)(m1(b)(2)(iv)(m)(2) or (4) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Tejas Gas Corp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b734 (b) or Code Section 743(b743 (b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m1 (b) of the Regulations(2) (iv) (m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Agreement of Limited Partnership (Detroit Radio, LLC)

Section 754 Adjustments. To the extent an adjustment to the ----------------------- adjusted tax basis of any Partnership asset pursuant to Section under Code section 734(b) or Section Code section 743(b) of the Code is required, pursuant to Section section 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such the adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basisthe tax basis of the asset) and such that gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section that Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Hob Entertainment Inc /De/)

Section 754 Adjustments. To Pursuant to Treasury ------------------------- Regulations section 1.704-1 (b)(2)(iv)(m), to the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section under Code section 732, 734(b) or Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(m) of the Regulations, required to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Horton D R Inc /De/)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) of the Code or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulationsl(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (General Public Utilities Corp /Pa/)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) of the Code or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulationsl(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, to be taken in account in maintaining Capital Accounts pursuant to Section 4.10 and Treasury Regulation § 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts), the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) asset or as an item of loss (if the adjustment decreases such basis) and such . Such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are Account or adjustments required to be adjusted pursuant to such section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.7041 .704-1(b)(2)(iv)(ml(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Duke Realty Limited Partnership/)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section Sections 1.704-1(b)(2)(iv)(m1(b)(2)(iv)(M)(2) or (4) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Tejas Gas Corp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section Code Sec. 734(b) or Section Code Sec. 743(b) of the Code is required, pursuant to Section Treas. Reg. Sec. 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases increase the basis of the asset) asset or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the RegulationsSection.

Appears in 1 contract

Sources: Limited Partnership Agreement (MCN Corp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(mRegulations Sections 1.704- 1(b)(2)(iv)(m)(2) of the Regulationsor (4), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Criimi Mae Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) of the Code or Section 743(b743(c) of the Code is required, pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the RegulationsTreasury Regulations Section 1.704-1(b)(2)(iv)(m).

Appears in 1 contract

Sources: General Partnership Agreement (Firsthand Technology Value Fund, Inc.)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section said Section of the Treasury Regulations.

Appears in 1 contract

Sources: Agreement With Respect to Retained Rights (Barnwell Industries Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the General Partner and Limited Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Lexreit Properties Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Duke Realty Investments Inc)

Section 754 Adjustments. To the extent that the Partnership makes an election pursuant to Code section 754, the amount of any adjustment to the adjusted tax basis of any Partnership asset pursuant to Section Code section 734(b) or Section 743(b) of the Code that is required, pursuant to Section Regulations section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) the basis of the asset), and such the gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the RegulationsRegulations section.

Appears in 1 contract

Sources: Limited Partnership Agreement (First Investors Financial Services Group Inc)

Section 754 Adjustments. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to in accordance with Code Section 734(b) or Section 743(b) of the Code is required, required pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section sections of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Colony Capital, Inc.)

Section 754 Adjustments. To the extent that an adjustment adjust to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is requiredrequired to be taken into account, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basis) the tax basis of the asset), and such gain or loss shall be specially allocated to the Partners in a manner consistent accordance with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the RegulationsRegulations Section 1.704-1(b)(2)(iv)(m).

Appears in 1 contract

Sources: Limited Partnership Agreement (Concepts Direct Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) of the Code or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m1(b) of the Regulations(2) (iv) (m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulationsl(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations. 64 2.

Appears in 1 contract

Sources: Agreement of Limited Partnership (American Industrial Properties Reit Inc)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section Treas. Regs. § 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Fleetwood Homes of Florida, Inc.)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Section 734(b) or Section 743(b743(c) of the Code is required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m) of the Regulationsl(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section Section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Suburban Propane Partners Lp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m) of the Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the Treasury Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Iroquois Gas Transmission System Lp)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset Property is required pursuant to Code Section 734(b) or Section 743(b) of the Code is required, pursuant to and Regulations Section 1.704-1(b)(2)(iv)(m1(b)(2)(iv)(m)(2) of the Regulationsor (4), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the assetsuch Partnership Property) or loss (if the adjustment decreases such basis) ), and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such section of the Code Sections and Regulations.

Appears in 1 contract

Sources: Limited Partnership Agreement (Insignia Properties Trust /)