definiens: for a Member means such Member 's Capital Account ( i ) reduced by the net adjustments, allocations and distributions described in Treasury Regulation Sections 1.704 - 1(b)(2)(ii)(d)(4 ), ( 5 ) and ( 6 ) which, as of the end of the Company 's taxable year are reasonably 4 < PAGE > expected to be made to such Member, and ( ii ) increased by the sum of ( A ) the amounts a Member is obligated to restore to its Capital Account or is deemed obligated to restore pursuant to the penultimate sentences of Treasury Regulation Sections 1.704 - 2(g)(1 ) and 2(i)(5 ), ( B ) the excess, if any, of such Member 's Capital Contribution over such Member 's actual paid - in capital contribution and ( C ) that portion of any indebtedness of the Company ( other than as defined in Treasury Regulation Section 1.704 - 2(b)(4 ) ) with respect to which the Member bears the economic risk of loss that such indebtedness would not be repaid out of the assets of the Company if all of the assets of the Company were sold at their respective book values as of the end of the fiscal period and the proceeds from the sales together with any amounts described in clauses ( A ) and ( B ) above, were used to pay the liabilities of the Company