THE INTENTION OF THE PARTIES a) The truth and accuracy of the foregoing recitals are acknowledged and confirmed by all the parties and the recitals form part of this Agreement.
THE INTENTION OF THE PARTIES. It is the intention of the parties to ---------------------------- this Distribution Agreement that, for United States federal income tax purposes, the Contribution and the Distribution shall qualify as tax-free transactions under Sections 368(a)(1)(D) and 355 of the Internal Revenue Code of 1986, as amended (the "Code"). The parties agree as follows:
