74 nonrecourse debt minimum gain, computed immediately before the hypothetical sale of assets, minus (in) in the case of the General Partner, any obligation of the General Partner to make a capital contribution to the Partnership pursuant to Section 18.6 or Annex A of the Agreement if the Partnership were dissolved at the time, plus (iv) in the case of each Limited Partner, the Limited Partner's share of the hypothetical capital contnbution of the General Partner described in clause (iv), minus (v) the Partner's obligation to make any Capital Contnbution at the time pursuant to Section 7 of this Agreement.
(b) If additional Partners are admitted to the Partnership subsequent to the Organization Date, the expense of the Management Fee and Organization and Offering Expenses shall be specially allocated among all of the Partners such that each Partner has been allocated total amounts of Management Fee expense and Organization and Offering Expenses since the inception of the Partnership equal to the amounts such Partner would have been allocated had all of the Partners been admitted to the Partnership on the Organization Date.
(c) For income tax purposes only, each item of income, gain, loss and deduction of the Partnership shall be allocated among the Partners in the same manner as the corresponding items of Net Profits and Net Losses and specially allocated items are allocated for Capital Account purposes; provided, that in the case of any Partnership asset the Carrying Value of which differs from its adjusted tax basis for United States federal income tax purposes, income, gain, loss and deduction with respect to such asset shall be allocated solely for income tax purposes in accordance with the principles of Sections 704(b) and (c) of the Code (in any permitted manner determined by the General Partner) so as to take account of the difference between Carrying Value and adjusted basis of such asset. (d) If a Limited Partner unexpectedly receives adjustments, allocations or distributions described in Treasury Regulation Sections 1.704-l(b)(2)(n)(d)(4), (5), or (6), such Limited Partner will be specially allocated items of taxable income and gain in an amount and manner sufficient to eliminate as quickly as possible