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This excerpt taken from the DTV 8-K filed Apr 28, 2005. “Adjusted Capital Account Deficit”—The deficit balance (if any) in a Member’s
Capital Account after (a) crediting to such Capital Account any amount which
such Member is obligated to restore pursuant to the Agreement or is deemed
obligated to restore pursuant to the minimum gain chargeback provisions in
Regulations sections 1.704-2(g)(1) and 1.704-2(i)(5) and (b) charging to such
Capital Account any adjustments, allocations or distributions described in the
qualified income offset provisions in Regulations section
1.704-1(b)(2)(ii)(d)(4), (5) or (6) which are required to be charged to such Capital
Account pursuant to this Addendum.
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