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7.12. Identity of Distributees. Distributions shall be made only to persons who, according to the books and records of the Partnership, are the owners of record of partnership interest on a date to be determined by the Administrative General Partner. Neither the General Partners nor the Partnership shall incur any liability for making distributions in accordance with the preceding sentence, whether or not the General Partners has knowledge or notice of any transfer of ownership of any partnership interests. 7.13. Sharing Between Transferor and Transferee. If an interest in the Partnership is transferred, the income, gains, losses and deductions allocable to the interest transferred for the Accounting Period during which the transfer occurred will be allocated between the transferor and transferee of the interest in proportion to the time during the Accounting Period that the interest was owned by the transferor and transferee. Credits shall be allocated to the party who owned the interest at the time that the property giving rise to the credit was placed in service. Each transferee will be credited with the capital account of the transferee's transferor. If a transferor transfers less than all of the transferor's interest in the Partnership, the capital account will be allocated in proportion to the fraction of the interest respectively transferred and retained. 7.14. Revaluation Adjustment. 7.14.1. The Administrative General Partner, upon advice of the Partnership's tax counsel that the Partnership is authorized pursuant to the provisions of Treasury Regulations Section 1.704 -1(b) (2)(iv)(f) and that it is in the Partners' interest to do so, shall cause an increase or decrease in the Partners' Capital Accounts to reflect a revaluation of Partnership property (including intangible assets such as goodwill) on the Partnership books. Any such revaluation shall be made strictly in compliance with the provisions of Treasury Regulations Section 1.704- 1(b)(2) (iv)ft including without limitation: (a) such adjustments shall (r) be based on the fair market value of Partnership properly (as agreed to by the Partners (as hereinafter provided) and taking IRC Section 7701 [g] into account) on the date of adjustment and (ii) reflect the manner in which the unrealized income, gain, loss or deduction inherent in such property (that has not been previously reflected in the Capital Accounts) would be allocated among the Partners if there were a taxable disposition of such property for its fair market value at the date of adjustment; (b) the Capital Accounts shall be adjusted in accordance with the provisions of Treasury Regulations Section 1.704- 1(b)(2)(iv)(g) for allocations of depreciation, depletion, amortization gain or loss (all as computed for book purposes) with respect to such property following the date of adjustment; and (c) the Partners' shares of depreciation, depletion, amortization, gain or loss (all as computed for tax purposes), with respect to such property, shall be determined so as to take account of the variation between the adjusted tax basis and book value of such property in the same manner as under IRC Section 704(c) following the date of adjustment. 7.14.2. In accordance with the provisions of Treasury Regulations Section 1.704- 1(b)(2)(iv)(g), the amount of book depreciation, depletion or amortization, for a period, with respect to any Partnership Properly, is the amount that bears the same relationship to the book value xnitdal W AgtOemene - s3nea ana 9.1.159.1.15 7.0 80A -109