Traditional Method. Notwithstanding any provision of the Partnership Agreement, the Partnership and the Subsidiary Partnership shall use the "traditional method" under Regulations Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code (with a "curative allocation" to offset the effects of the "ceiling rule," upon any sale of a Protected Property).
Appears in 2 contracts
Sources: Tax Protection Agreement (Brandywine Realty Trust), Tax Protection Agreement (Brandywine Realty Trust)