Risk of Loss Allocation. Any item of “partner nonrecourse deduction” (as defined in Treasury Regulation Section 1.704-2(i)(2)) with respect to a “partner nonrecourse debt” (as defined in Treasury Regulation Section 1.704-2(b)(4)) shall be allocated to the Partner or Partners who bear the economic risk of loss for such Partner Nonrecourse Debt in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Sources: Limited Partnership Agreement (Clearday, Inc.), Merger Agreement (Superconductor Technologies Inc), Merger Agreement (Superconductor Technologies Inc)