For income tax purposes, all items of taxable income, gain, loss, deduction and credit will be allocated among the Partners at the end of each fiscal year pro rata in proportion to their respective capital accounts in the Fund.

In light of the fact that the Fund does not intend to make distributions, to the extent the Fund's investment activities are successful, Limited Partners should expect to receive allocations of income and loss, and may incur tax liabilities from an investment in the Fund without receiving cash distributions from the Fund with which to pay those liabilities. Since the Fund has no lock-up period Partners may make withdrawals once a month for any purpose.