DISALLOWANCE OF DEDUCTIONS. Notwithstanding any other provisions of this Agreement, in the event that any fees paid to the General Partner or its affiliates pursuant to this Agreement and deducted by the Partnership in reliance on Section 707(a) and /or Section 707(c) of the Internal Revenue Code of 1986, as amended (the Code), are disallowed as deductions to the Partnership on its federal income tax return and treated as Partnership distributions, the General Partner shall be allocated items of Partnership income, if any, in the year such fees were paid, equal to the amount of such fees for which deductions were disallowed.
Appears in 2 contracts
Sources: Limited Partnership Agreement (American Gas & Technology LP), Limited Partnership Agreement (American Gas & Technology LP)