Extract to table

1 — Defined Terms As used in Articles VIII through XII of this Agreement, the following terms shall have the meanings set forth below

Capitalized terms used in this Article and not otherwise defined herein shall have the meanings ascribed to them elsewhere in this Agreement

704-1(b)(2)(ii)(d) and shall be interpreted consistently therewith

704-1(b)(2)(ii)(g); and (iv) the grant of a Profits Interest (including any Class B Units or Class C Units) if the Managing Member determines that such grant constitutes a revaluation event for Capital Account purposes; and (c) The Book Value of any Company asset distributed to any Member shall be the fair market value of such asset on the date of distribution

If the Book Value of an asset has been determined or adjusted pursuant to clause (a) or (b) above, such Book Value shall thereafter be adjusted by the Book Depreciation taken into account with respect to such asset for purposes of computing Net Income and Net Loss

The Unvested component of the Class B Units shall be treated as Profits Interests for federal income tax purposes under Revenue Procedure 93-27, 1993-2 C