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offsetting increases to such Partner's Capital Account which are <br /> reasonably expected to occur during (or prior to) the <br /> Partnership's taxable years in which such distributions are <br /> reasonably expected to be made (other than increases pursuant to <br /> a minimum gain chargeback under Temporary Treasury Regulations <br /> Section 1.704- 1T(b)(4)(iv)(e)). <br /> 6.7. Low Income Housing Credits. <br /> (a) All expenditures includible in the computation of <br /> the low income housing credit under Section 42 of the Code and <br /> under Section 23610.5 of the California Code shall be allocated <br /> among the Partners in the manner in which the deductions arising <br /> from those expenditures are allocated among the Partners for the <br /> relevant taxable year. It is the intention of the Partners that <br /> those expenditures be allocated 99% to the Limited Partners in <br /> proportion to their Percentage Interests and 1% to the General <br /> Partner. <br /> (b) Any recapture of any Low Income Housing Credits shall <br /> be allocated among the Partners in the same manner in which the <br /> Partners share the expenditures giving rise to that credit. <br /> 6.8. Appreciated Property. <br /> (a) Gain or loss resulting from any disposition of <br /> Partnership property with respect to which gain or loss is <br /> recognized for federal income tax purposes shall be computed by <br /> reference to the Gross Asset Value of the property disposed of, <br /> notwithstanding that the adjusted tax basis of such property <br /> differs from its Gross Asset Value. <br /> -24- <br />