IPO II, A Partnership, Gerald R. Forsythe, Tax Matters Partner - Page 4

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                    2.4 Liability to Third Parties.  Except as otherwise              
               provided by the Act,[3] the debts, obligations and                     
               liabilities of the Company, whether arising in contract,               
               tort, strict liability or otherwise, shall be solely the               
               debts, obligations and liabilities of the Company, and no              
               Member or Manager of the Company shall be obligated                    
               personally for any such debt, obligation or liability of the           
               Company solely by reason of being a Member or acting as a              
               Manager of the Company.                                                
                         *    *    *    *    *    *    *                              
                    5.3  Liability of Members to the Company.  A Member               
               shall be liable to the Company for capital contributions as            
               and to the extent provided by the Act.                                 
                         *    *    *    *    *    *    *                              
                    7.1  Allocations of Profits and Losses.  All profits              
               and losses of the Company (which for all purposes of this              
               Agreement shall mean the Company’s net income and net loss             
               as determined for federal income tax purposes) for each                
               fiscal year (or part thereof) shall be allocated to the                
               Members for both financial accounting and income tax                   
               purposes in proportion to the number of Units held by each             
               respective Member.  Each item of income, gain, loss,                   
               deduction, credit or tax preference of the Company entering            
               into the computation of such profits or losses, or                     
               applicable to the period during which any such profits or              
               losses were realized, shall be considered allocated between            
               the Members in the same proportion as profits and losses are           
               allocated to each Member.  Profits and losses of the Company           
               shall be determined for each fiscal year in accordance with            
               the accounting method followed by the Company for federal              
               income tax purposes, applied in a consistent manner.                   

               Mr. Forsythe also owns 70 percent (i.e., 28 of 40 shares) of           
          the outstanding shares of Indeck Energy Services, Inc. (Indeck              
          Energy).  Indeck Energy was a C corporation in 1997 but elected             

               3  The operating agreement defines “Act” as “the Illinois              
          Limited Liability Company Act, effective January 1, 1994, as                
          amended from time to time.”                                                 




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