and Provisional Members reasonably determine that such adjustments are necessary or
appropriate to reflect the relative economic interest of the Members. Any such adjustments shall
be reflected by corresponding adjustments to the Capital Accounts which reflect the manner in
which the unrealized income, gain, loss, or deduction inherent in such property (that has not been
reflected in the Capital Accounts previously) would be allocated among the Members if there
were a taxable disposition of such assets for such fair market values.
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