Chargeback of Partner Nonrecourse Debt Minimum Gain. Notwithstanding the other provisions of this Article V (other than Section 5.3(a), except as provided in Regulation Section 1.704-2(i)(4)), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any Partnership Fiscal Year, any Partner with a share of Partner Nonrecourse Debt Minimum Gain, determined in accordance with Section 1.704-2(i)(5) of the Regulations, shall be allocated items of Partnership income and gain for such period (and if necessary, subsequent periods) in an amount equal to such Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt, determined in accordance with Regulations Section 1.704-2(i)(4). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Section 1.704-2(i)(4) and 1.704-2(j)(2) of the Regulations. This Section 5.3(b) is intended to comply with the minimum gain chargeback requirement in Section 1.704(i)(4) of the Regulations and shall be interpreted consistently therewith.
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Chargeback of Partner Nonrecourse Debt Minimum Gain. Notwithstanding the other provisions of this Article ARTICLE V (other than Section SECTION 5.3(a), except as provided in Regulation Section 1.704-2(i)(4)) of the Regulations), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain during any Partnership Fiscal Year, any Partner with a share of Partner Nonrecourse Debt Minimum Gain, determined in accordance with Section 1.704-2(i)(5) of the Regulations, shall be allocated items of Partnership income and gain for such period (and if necessary, subsequent periods) in an amount equal to such Partner's share of the net decrease in Partner Nonrecourse Debt Minimum Gain attributable to such Partner Nonrecourse Debt, determined in accordance with Regulations Section 1.704-2(i)(4)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Section Sections 1.704-2(i)(4) and 1.704-2(j)(2) of the Regulations. This Section SECTION 5.3(b) is intended to comply with the minimum gain chargeback requirement in Section 1.704(i)(41.704-2(i)(4) of the Regulations and shall be interpreted consistently therewith.
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