Trustee Election. In mutual consideration for each Certificateholder's purchase of a Certificate, each Certificateholder acknowledges that it intends that the Trust be excluded from the application of the rules of subchapter K of the Code in the event that the Internal Revenue Service successfully recharacterizes the Trust as a partnership for federal income tax purposes, and will be deemed to have consented to the making of a protective election pursuant to Treasury Regulation Section 1.761-2 as of the date hereof.
Appears in 4 contracts
Samples: Receipts on Corporate Securities Trust Series NSC 1998-1, Receipts on Corporate Securities Trust Series BNSF 1998-1, Receipts on Corporate Securities Trust Series BLS 1998-1
Trustee Election. In mutual consideration for each Certificateholder's purchase of a Certificate, each Certificateholder acknowledges that it intends that the Trust be excluded from the application of the rules of subchapter K of the Code in the event that the Internal Revenue Service successfully recharacterizes the Trust as a partnership for federal income tax purposes, and will be deemed to have consented to the making of a protective election pursuant to Treasury Regulation Section 1.761-2 as of the date hereof.]
Appears in 1 contract
Samples: Series (Prudential Securities Structured Assets Inc)
