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notwithstanding, any items of income, gain, loss or deduction for a Fiscal Period ("Current Fiscal Period') attributable to any Partnership matter or transaction occurring during a prior Fiscal Period (such ... Capital Accounts of all Partners as of the beginning of the Current Fiscal Period may, at the sole discretion of the General Partner, be allocated among the Partners (including persons ... Period. In the case of a person who is a Partner during the Current Fiscal Period, the Prior Fiscal Period Items shall be considered an item of Net Profit