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Cash from Operations"), Paragraph 7.11 (entitled Distribution of Cash from Capital Events) and subparagraph 11. 3.3. during each such year, 7.4. Allocation of Credits. All income tax credits of the Partnership shall be allocated in accordance with the ratio in which the profits of the Partnership are allocated (or would be allocated) among the Partners pursuant to Paragraph 73 (entitled "Allocation of Profits"), for the Partnership's taxable year during which the property which gives rise to the income tax credit is placed in service, regardless of whether the Partnership has a profit or a loss for such taxable year, However, if the ratio in which the Partners divide the profits of the Partnership changes during the taxable year of the Partnership in which such property is placed in service, the ratio effective for the date on which the property is placed in service shall apply. To the extent that any income tax credits allocated to the Partners ate subject to recapture, such recapture income shall be allocated to the Partners to whom such tax credits were previously allocated. 7.5. Minimum Gain. Notwithstanding any other provision of this Agreement to the contrary and with a priority allocation pursuant to Treasury Regulations Section 1.704-1 [b][4]fiv] [e]: 7.5.1. The Limited Partners shall not be allocated loss or deduction (or items thereot) attributable to nonrecourse debt which is secured by Partnership Property if such allocation would cause the sum of the deficit capital account balances of the Partner receiving such allocation (increased by the additional capital contributions such Partner is obligated to make pursuant to Paragraph 6.1 [entitled "Initial Capital"]) to exceed the Minimum Gain (determined at the end of the Partnership's taxable year to which such allocation relates) a Limited Partner's allocable share of the minimum gain shall be equal to the product of (a) the Minimum Gain, times (b) such Partner's then Partnership Interest. 7.5.2. The Partners with deficit Capital Account balances resulting in whole or in part from allocations of loss or deduction (or item thereof) attributable to nonrecourse debt which is secured by Partnership property shall, to the extent possible, be allocated income or gain (or item thereol) until the sum of such deficit Capital Account balances equals the Minimum Gain, 7.5.3. For purposes of computing the sum of the Partners' deficit Capital Account balances, if any property (including cash) is held by the Partnership at the end of the Partnership taxable year and there is a reasonable expectation that such property will be distributed to a Partner (other than in liquidation of the Partnership) prior to a corresponding increase in Stich Parincr's Capital Account, such property shall be treated as having been distributed to such Partner on the last day of such taxable year, 7,5A, The Minimum Gain shall be reduced by the cost of any capital improvements to be made to the subject property and the amount of any principal payments to be made with respect to the non recourse debts secured by such property to the extent there is a Initial LP Agreement , Santa Me 9.1.159 1.15 80A-1 05