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balances until all Capital Account balances have been reduced to <br /> zero and thereafter to the Partners in accordance with their <br /> Percentage Interests. <br /> 6.4. Qualified Income Offset. <br /> Notwithstanding Sections 6.2 and 6.3 above, in the event <br /> a Partner receives any adjustment, allocation, or distribution <br /> described in Treasury Regulations Section 1.704- 1(b)(2)(ii) <br /> (d)(4), (5) or (6), that Partner shall be allocated items of <br /> income and gain in an amount and manner sufficient to eliminate <br /> any deficit balance in that Partner's Capital Account caused by <br /> any adjustment, allocation, or distribution as quickly as <br /> possible. This special allocation shall be taken into account in <br /> computing subsequent allocations of Profits so that the net <br /> amount of allocations of Profits, Losses and all other items, to <br /> the extent possible, shall be equal to the net amount that would <br /> have been allocated if the unexpected adjustment, allocation or <br /> distribution had not occurred. <br /> 6.5. Minimum Gain Chargeback. <br /> If during any tax year of the Partnership there is a net <br /> decrease in the Partnership's minimum gain (as defined in <br /> Temporary Treasury Regulations Section 1.704- 1T(b)(4)(iv)(c)), <br /> Partners with a deficit Capital Account balance at the end of <br /> that year (increased by a Partner's share of the Partnership's <br /> minimum gain as determined pursuant to Temporary Treasury <br /> Regulations Section 1.704- 1T(b)(4)(iv)(f)) shall be allocated, <br /> before any other allocation, items of profits and gain• for such <br /> year in the amount and in the proportions needed to eliminate <br /> -22- <br />