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EFTA00617557Set 9

78p41,041w

computed in accordance with applicable Treasury Regulations, or (b) with respect to each Partner Nonrecourse Debt, the amount of gain that would be realized by the Partnership if it disposed ... taxable transaction) the Partnership assets that are subject to such Partner Nonrecourse Debt in full satisfaction of such Partner Nonrecourse Debt, computed in accordance with applicable Treasury Regulations. "Net Profit ... Parallel Funds" shall have the meaning assigned to it in Section 5.5(cl. "Partner Nonrecourse Debt" shall mean any nonrecourse debt of the Partnership for which any Partner bears

https://www.justice.gov/epstein/files/DataSet%209/EFTA00617557.pdf

EFTA01084769Set 9

78p41,041w

computed in accordance with applicable Treasury Regulations, or (b) with respect to each Partner Nonrecourse Debt, the amount of gain that would be realized by the Partnership if it disposed ... taxable transaction) the Partnership assets that are subject to such Partner Nonrecourse Debt in full satisfaction of such Partner Nonrecourse Debt, computed in accordance with applicable Treasury Regulations. "Net Profit ... Parallel Funds" shall have the meaning assigned to it in Section 5.5(cl. "Partner Nonrecourse Debt" shall mean any nonrecourse debt of the Partnership for which any Partner bears

https://www.justice.gov/epstein/files/DataSet%209/EFTA01084769.pdf

EFTA01084507Set 9

2006-12-0649p19,072w

other provision of this Schedule, if there is a net decrease in partner nonrecourse debt minimum gain attributable to a partner nonrecourse debt during any Fiscal Year, each Member ... share of the partner nonrecourse debt minimum gain attributable to such partner nonrecourse debt, determined in accordance with Section 1.704-2(i)(5) of the Regulations, shall be specifically allocated ... amount equal to such Member's share of the net decrease in partner nonrecourse debt minimum gain attributable to such partner nonrecourse debt, determined in accordance with Section

https://www.justice.gov/epstein/files/DataSet%209/EFTA01084507.pdf

EFTA00614617Set 9

2015-03-0942p11,172w

Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions ... Section 7.05, (iii) minus such Partner's share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. (b) Special Allocation Provisions. (i) Minimum Gain Chargeback. Notwithstanding any other provision ... amount with respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614635 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that

https://www.justice.gov/epstein/files/DataSet%209/EFTA00614617.pdf

EFTA00614659Set 9

2015-03-0942p11,174w

Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions ... Section 7.05, (iii) minus such Partner's share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. (b) Special Allocation Provisions. (i) Minimum Gain Chargeback. Notwithstanding any other provision ... amount with respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614677 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that

https://www.justice.gov/epstein/files/DataSet%209/EFTA00614659.pdf

EFTA00803515Set 9

2015-03-0942p18,911w

Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions ... Section 7.05, (iii) minus such Partner's share of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. (b) Special Allocation Provisions. (i) Minimum Gain Chargeback. Notwithstanding any other provision ... amount with respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00803533 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that

https://www.justice.gov/epstein/files/DataSet%209/EFTA00803515.pdf

EFTA01391349Set 10

1p408w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391349.pdf

EFTA01393578Set 10

1p409w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393578.pdf

EFTA01390098Set 10

1p408w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01390098.pdf

EFTA01354154Set 10

1p408w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354154.pdf

EFTA01386559Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01386559.pdf

EFTA01382955Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01382955.pdf

EFTA01354980Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354980.pdf

EFTA01389249Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389249.pdf

EFTA01355357Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01355357.pdf

EFTA01392334Set 10

1p408w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392334.pdf

EFTA01394104Set 10

1p409w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394104.pdf

EFTA01394504Set 10

1p408w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394504.pdf

EFTA01354585Set 10

1p410w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354585.pdf

EFTA01353792Set 10

1p409w

forth in 6.2.1. Partner Nonrecourse Has the same meaning as the term "partner nonrecourse debt" set forth in Debt Treasury Regulations Section 1.704-2(b)(4). Partner Nonrecourse An amount ... with respect to each Partner Nonrecourse Debt, equal to the Debt Minimum Gain Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01353792.pdf