definiens: means, with respect to any asset, the asset ’s adjusted basis for federal income tax p urposes ; provided, however, that ( i ) the initial Carrying Va lue of any asset contributed to the Company shall b e adjusted to equal its gross fair market value at the time of its contribution and ( ii ) if elected by the Compan y, the Carrying Values of all assets held by the Company shall be a djusted to equal their respective gross fair market values ( taking Code Section 7701(g ) into account ) at any t ime specified in Treasury Regulation Section 1.704 - 1(b)(2)(iv)(f ) . The Carrying Value of any asset who se Carrying Value was adjusted pursuant to the prec eding sentence thereafter shall be adjusted in accordance with the provisions of Treasury Regulation Section 1.704 - 1(b)(2)(iv)(g ) . The Carrying Value of the assets of the Company were adjusted immediately prior to the admission of [COMPANY] to the Company on the Agreement Date