Debt Allocation. The General Partner may allow any Limited Partner to guarantee on a "bottom dollar basis," an amount of indebtedness of the Partnership or any successor thereto, as is necessary from time to time to provide an allocation of debt to such Limited Partner equal to the amount of debt then required to be allocated to such Limited Partner to enable such Limited Partner to avoid recognizing gain pursuant to Section 731(a)(1) of the Code as a result of a deemed distribution of money to such Limited Partner pursuant to Section 752(b) of the Code.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Baron Capital Trust), Limited Partnership Agreement (Baron Capital Trust)