Traditional Method. Each Company (and each Subsidiary) shall adopt the traditional method under Treasury Regulations Section 1.704-3(b) for purposes of making allocations under Section 704(c) of the Code (which shall include, for purposes of this Article V, allocations pursuant to Treasury Regulations Section 1.704-3(a)(6)) with respect to Protected Property, with no “curative” or “remedial” allocations under Section 704(c) of the Code.
Appears in 2 contracts
Sources: Tax Protection Agreement (Clipper Realty Inc.), Tax Protection Agreement (Clipper Realty Inc.)