definiens: as defined in Treasury Regulation Section 1.704 - 3(b ) . If and when theCapital Accounts of the Members are required to be adjusted pursuant to Regulation Sections 1.704 - 1(b)(2)(iv)(f ) or(g ) with respect to a revaluation of any asset of the Company, then subsequent allocations of income, gain, loss, anddeduction, including depreciation or deductions for cost recovery with respect to such asset, shall take into accountany variation between the then existing adjusted basis of such asset for federal income tax purposes and the agreedvalue of such asset, as such computations may be required under Sections 704(b ) and 704(c ) of the Code andRegulation Section 1.704 - 1(b)(4)(i ) . Any elections or other decisions relating to such allocations shall be made by theBoard in its sole and absolute discretion