Allocation of Excess Nonrecourse Liabilities. For purposes of section 752 of the Code and the regulations thereunder, the excess nonrecourse liabilities of the Company (within the meaning of Treas. Reg. Section 1.752-3(a)(3)), if any, shall be allocated to each Member in accordance with their respective Allocation Interests.
Appears in 3 contracts
Samples: Operating Agreement (Eacc Camps Inc), Operating Agreement (Eacc Camps Inc), Operating Agreement (Eacc Camps Inc)
Allocation of Excess Nonrecourse Liabilities. For purposes of section 752 of the Code and the regulations thereunder, the excess nonrecourse liabilities of the Company Partnership (within the meaning of Treas. Reg. Section 1.752-(S) 1.752- 3(a)(3)), if any, shall be allocated to each Member the Members in accordance with their respective Allocation Percentage Interests.
Appears in 3 contracts
Samples: Operating Agreement (Atria Communities Inc), Operating Agreement (Atria Communities Inc), Operating Agreement (Atria Communities Inc)
Allocation of Excess Nonrecourse Liabilities. For purposes of section 752 of the Code and the regulations thereunder, the excess nonrecourse liabilities of the Company (within the meaning of Treas. Reg. Section § 1.752-3(a)(3)), if any, shall be allocated to each Member in accordance with their respective Allocation Interests.
Appears in 2 contracts
Samples: Operating Agreement (Pacific Export Resources, LLC), Operating Agreement (Pacific Export Resources, LLC)
Allocation of Excess Nonrecourse Liabilities. For purposes of section Section 752 of the Code and the regulations thereunder, the excess nonrecourse liabilities of the Company (within the meaning of Treas. Reg. Section 1.752-3(a)(3)), if any, shall be allocated to each Member in accordance with their respective Allocation Interests.
Appears in 1 contract
Samples: Operating Agreement (Eacc Camps Inc)
Allocation of Excess Nonrecourse Liabilities. For purposes of section 752 of the Code and the regulations thereunder, the excess nonrecourse liabilities of the Company (within the meaning of Treas. Reg. Section §1.752-3(a)(3)), if any, shall be allocated to each Member in accordance with their respective Allocation Interests.the Members as follows:
Appears in 1 contract
Samples: Operating Agreement (Pacific Export Resources, LLC)