Common use of Partner Nonrecourse Debt Minimum Gain Clause in Contracts

Partner Nonrecourse Debt Minimum Gain. Except as otherwise ------------------------------------- provided in Treasury Regulations Section 1.704-2(i)(4), if there is a net decrease in "partner nonrecourse debt minimum gain" attributable to a "partner nonrecourse debt" during any Fiscal Year, each Member who has a share of such "partner nonrecourse debt minimum gain" will be specially allocated items of income and gain for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to that share. This Section 9.2(d) is intended to comply with the "minimum gain chargeback" requirements of Treasury Regulations Section 1.704-2 and will be interpreted accordingly.