EFTA Document EFTA01386199

AGP LP 519 Alpha Group Capital Paul Barrett Partnership Agreement, whether or not any income is paid out to such Partner. Such items of taxable income, deduction and loss will be required to be taken into account in the taxable year of the Partner in which the fiscal year of the Partnership ends. Under Section 7704 of the Internal Revenue Code of 1986, as amended (the "Code"), a partnership that meets the definition of a "publicly traded partnership' may be taxable as a corporation. It is e