Offsetting Allocations. In the event items of Fund income, gain, loss or deduction are allocated pursuant to Sections 4.5 through 4.7, offsetting allocations of items of Fund income, gain, loss or deduction shall subsequently be made to the Members in such manner as the Managing Member deems appropriate so as to achieve as nearly as possible the results that would have been achieved had Sections 4.5 through 4.7 not been included in this Agreement and all items of Fund income, gain, loss and deduction had been allocated pursuant to Sections 4.2 through 4.4 (except that no allocation shall be made that would contravene Treasury Regulation section 1.704-1(b)(2)(ii)(d)).
Appears in 3 contracts
Sources: Operating Agreement, Operating Agreement, Limited Liability Company Operating Agreement