Common use of Federal Income Tax Treatment Clause in Contracts

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's interest in the Partnership under this Article 13, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's Partnership interest will, for federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's share of the Partnership's "unrealized receivables," as defined in Code Section 751(c), which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's share of "unrealized receivables." Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's share of the Partnership's "unrealized receivables."

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's ’s interest in the Partnership under this Article 1314, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's ’s Partnership interest will, for federal Federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's ’s share of the Partnership's "’s “unrealized receivables," ” as defined in Code Section 751(c), ) which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's ’s share of "“unrealized receivables." ” Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's ’s share of the Partnership's "’s “unrealized receivables."”

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase liquidate any Partner's ’s interest in the Partnership under this Article 13XIII, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's ’s Partnership interest will, for federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's ’s share of the Partnership's "’s “unrealized receivables," ” as defined in Code Section 751(c), which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's ’s share of "“unrealized receivables." ” Neither the Partnership nor the General Partner shall be liable to any Person person or entity for any inaccuracy in determining any such Partner's ’s share of the Partnership's "’s “unrealized receivables."”

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's interest in the Partnership under this Article 1314, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's Partnership interest will, for federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's share of the Partnership's "unrealized receivables," as defined in Code Section 751(c), ) which will be classified as a Code Section 736(a)(1) payment. The General Partner Partner, shall conclusively determine or cause to be determined any such Partner's share of "unrealized receivables." Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's share of the Partnership's "unrealized receivables."

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's ’s interest in the Partnership under this Article 13, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's ’s Partnership interest will, for federal Federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's ’s share of the Partnership's "’s “unrealized receivables," ” as defined in Code Section 751(c), which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's ’s share of "“unrealized receivables." ” Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's ’s share of the Partnership's "’s “unrealized receivables."”

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's ’s interest in the Partnership under this Article 13VII, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's ’s Partnership interest will, for federal Federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's ’s share of the Partnership's "’s “unrealized receivables," ” as defined in Code Section 751(c), ) which will be classified as a Code Section 736(a)(1736(a)(l) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's ’s share of "“unrealized receivables." ” Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's ’s share of the Partnership's "’s “unrealized receivables."”

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's interest in the Partnership under this Article 13, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's Partnership interest will, for federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's share of the Partnership's "unrealized receivables," as defined in Code Section 751(c), which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's share of "unrealized receivables." Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's share of the Partnership's "unrealized receivables."" 13.8

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase any Partner's interest in the Partnership under this Article 13VII, one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's Partnership interest will, for federal Federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's share of the Partnership's "unrealized receivables," as defined in Code Section 751(c), ) which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's share of "unrealized receivables." Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's share of the Partnership's "unrealized receivables."

Federal Income Tax Treatment. In the event the Partnership exercises the right to purchase liquidate any Partner's ’s interest in the Partnership under this Article 13, 14. one hundred percent (100%) of all payments made by the Partnership to such Partner hereunder in consideration for such Partner's ’s Partnership interest will, for federal income tax purposes, be classified as a Code Section 736(b) payment except for such Partner's ’s share of the Partnership's "’s “unrealized receivables," ” as defined in Code Section 751(c), ) which will be classified as a Code Section 736(a)(1) payment. The General Partner shall conclusively determine or cause to be determined any such Partner's ’s share of "“unrealized receivables." ” Neither the Partnership nor the General Partner shall be liable to any Person for any inaccuracy in determining any such Partner's ’s share of the Partnership's "’s “unrealized receivables."”