definiens: means, with respect to any asset, the asset ’s adjusted basis for federal income taxpurposes, except as follows : ( a ) The initial Gross Asset Value for any asset ( other than money ) contributed by a Member to theCompany shall be as determined by the Management Committee and the contributing Member ; ( b ) The Gross Asset Value of all Company assets shall be adjusted to equal their respective gross fairmarket values, as determined by the Management Committee immediately prior to any Adjustment Date ; ( c ) The Gross Asset Value of any Company asset distributed to any Member shall be adjusted to equal itsgross fair market value on the date of distribution ; A-2 ( d ) The Gross Asset Value of the Company ’s assets shall be increased ( or decreased ) to reflect anyadjustments to the adjusted basis of such assets pursuant to Code Section 734(b ) or Code Section 743(b ), but only tothe extent that such adjustments are taken into account in determining Capita ! Accounts pursuant to RegulationsSection 1.704 - l(b)(2)(iv)(m ) and Section A2(g ) of this Appendix 1 ; provided, however, that Gross Asset Value shall notbe adjusted pursuant to this subsection ( d ) to the extent that an adjustment pursuant to subsection ( b ) of thisdefinition is necessary or appropriate in connection with a transaction that would otherwise result in an adjustmentpursuant to this subsection ( d ) ; and ( e ) If the Gross Asset Value of an asset has been determined or adjusted pursuant to subsection ( a ), ( b)or ( d ) above, such Gross Asset Value shall thereafter be adjusted by the Depreciation taken into account from time totime with respect to such asset for purposes of computing Profits and Losses