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those deficits as quickly as possible. It is intended that this <br /> allocation of Partnership minimum gain be applied in a manner <br /> that satisfies the requirements of Temporary Treasury Regulations <br /> Section 1.704- 1T(b)(4)(iv)(e). <br /> 6.6. Deficit Balance. <br /> To the extent an allocation of profits or loss and gain <br /> or loss on the disposition of the Development would cause or <br /> increase a deficit balance in a Partner's Capital Account (beyond <br /> the amount of any deficit balance the Limited Partner, by reason <br /> of his share of minimum gain, is deemed obligated to restore <br /> pursuant to Temporary Treasury Regulations Section <br /> 1.704- 1T(b)(4)(iv)(£)) as of the end of the Partnership's taxable <br /> year to which such allocation relates, the allocation of profit <br /> and loss to all Partners shall be appropriately modified to make <br /> the minimum adjustment necessary to the allocation to such <br /> partner so as not to cause or increase a deficit, as the case may <br /> be, in that Partner's Capital Account. In determining the extent <br /> to which the previous sentence is satisfied, such Partner's <br /> Capital Account shall also be adjusted for each of the following: <br /> (a) Such Partner's Capital Account shall be reduced for <br /> allocations of loss which, as of the end of such year, are <br /> reasonably expected to be made to such Partner pursuant to <br /> Internal Revenue Code Sections 704(e)(2) and 706(d), and <br /> Paragraph (b)(2)(ii) of Treasury Regulations Section 1.751 -1. <br /> (b) Such Partner's Capital Account shall be reduced for <br /> distributions which, as of the end of such year, are reasonably <br /> expected to be made to such Partner, to the extent they exceed <br /> -23- <br />