any deficit balance in its Capital Account (as determined for purposes of Section 8.1(c)). Any special allocations of taxable income or gain pursuant to this Section 8.1(d) shall be taken into account in computing subsequent allocations of taxable income or gain, so that the net amount of any item so allocated to each Limited Partner pursuant to Section 8.1(c) shall, to the extent possible, be equal to the net amount that would have been allocated to each such Limited Partner if such unexpected adjustments, allocations or distributions had not occurred, (e) In the event any Partner has a deficit Capital Account at the end of any Allocation Penod which is in excess of the sum of (x) the amount such Partner is obligated to restore, if any, pursuant to any provision of this Agreement, and (y) the amount such Partner is deemed to be obligated to restore pursuant to the second sentences of Regulations Sections 1.704-2(g)(l) and 1.704-2(i)(5), each such Partner shall be specially allocated items of Partnership income and gain in the amount of such excess as quickly as possible; provided, that an allocation pursuant to this Section 8.1(e) shall be made only if and to the extent that a Partner would have a deficit Capital Account in excess of such sum after all other allocations provided for in this Section 8 have been tentatively made.
8.2 Distributions.
(a) Cash Distributions of Net
Profits, Realized Gains and Capital.
(l) Subject to retention for reserves or expenses, the General Partner shall distnbute (A) the proceeds of the sale of a Portfolio Secunty, or any portion thereof within 90 days of such sale, and (B) money which it determines represents dividend or interest income quarterly.
(u) Each distribution initially shall be tentatively apportioned among the Partners in proportion to their Required Capital. The amount so apportioned to the General Partner shall be distributed to the General Partner without giving regard to the priorities set forth in Sections 8.2(a)(u)(A) and (B). The amount so apportioned to each Limited Partner shall be further divided 75