Common use of Section 754 Adjustments Clause in Contracts

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) is required pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest Interest in the Company, 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 Members in accordance with Section 5.02(a), their Interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(21.704-(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section 734(b734(h) or Code Section 743(b743(6) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(21.704- l(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) 1.704- l(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the assetproperty) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704l .704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m )(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704l.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section Sections 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) 1 (b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(21(b) (2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(41(b)(2) (iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to under Internal Revenue Code Section §734(b) or Section §743(b) is required pursuant to under Treasury Regulation Section §1.704-1(b)(2)(iv)(m)(2) or Section §1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such the Member’s interest in the Company, the amount of such the 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 the basis) ), and such the gain or loss shall be specially allocated to the Members in accordance with Section 5.02(a), their interests in the Company in the event that Treasury Regulation Section §1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Partner to whom such the distribution was made in the event that Treasury Regulation Section §1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(21(b)(2)(iv)(m) )(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Companyits Interest, 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 Members in accordance with Section 5.02(a), proportion to their relative Percentage Interests in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Members to whom such distribution was made in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Section 1.704Sections 704-1(b)(2)(iv)(m)(2) or Section § 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Section Sections 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Section Sections 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b743 (b) of the Code is required pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such the Member’s interest Interest in the Company, 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 Members in accordance with Section 5.02(a), their Interests in the Company in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(21.704(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was wad made in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property pursuant to Code Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(41 (b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of such the Member’s interest in the Company's Units, 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 Members in accordance with Section 5.02(a), their Units in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution Distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.7041. 704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into in account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) 1 (b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section Sections 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 as an item of loss (if the adjustment decreases such basis) ), and such gain or loss shall be specially allocated to the Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section Sections 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of such Member’s its interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the event Company if Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution Distribution was made in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the CompanyPlan, the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the assetProperty) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Members in accordance with Section 5.02(a), their Percentage Interest in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company Fund asset pursuant to Code Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(2) or Section 1.704-Treasury Regulations §1.704- 1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member Partner in complete liquidation of such Member’s interest in the Companyits Fund Interest, 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 Members Partners in accordance with Section 5.02(a), their Percentage Interests in the event Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Partner to whom such distribution was made in the event Treasury Regulation Section Regulations §1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s its interest in the Company, 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 Members in accordance with Section 5.02(a), their Interests in the Company in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s his interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any asset of the Company asset pursuant to Code Section 734(b) or Section 743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) (4), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of such Member’s interest in the CompanyMembership Interests, 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 Members in accordance with Section 5.02(a), 6.1 in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, applies or to the Member Members to whom such distribution Distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.; and

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property pursuant to Code Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of such the Member’s interest in the Company's Units, 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 Members in accordance with Section 5.02(a), their Units in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution Distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(21.7041(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(41.7041(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743(b) is required pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the Company, 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 Members in accordance with Section 5.02(a5.03(a), in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s interest in the CompanyCompany Interest, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s his interest in the Company, 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 Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(21.7041(b)(2)(iv)(m)(2) applies, or to the Member to whom who such distribution was made in the event Treasury Regulation that Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of such Member’s 's interest in the Company, 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 basisbasis of the asset) and such gain or loss shall be specially allocated to the Members in accordance with Section 5.02(a), their interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property pursuant to Code Section section 734(b) or Section Code section 743(b) is required pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Regulations Section 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of such the Member’s interest in the Company's Interest, 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 Members in accordance with Section 5.02(a), their Interests in the Company in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution Distribution was made in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.