The Record Date for a distnbution of Portfolio Securities shall mean the date selected by the General Partner in the following manner. At any time that the General Partner shall determine to make a distnbution to the Partners pursuant to Section 8.2, the General Partner shall determine the value of any Portfolio Secunties to be distributed in kind and the Net Asset Value of the Partnership pursuant to Section 15 and the General Partner shall use its best efforts to effect such distribution within two (2) Business Days thereafter. The date of such value determination by the General Partner shall be the Record Date for such distribution. 8.3 Allocations of Net Profit and Net Loss: Distributions in Respect of Interests Transferred. If any Units are transferred during any Allocation Period, the Net Profit or Net Loss attributable to such Units and to the owners thereof for such Allocation Period shall be divided and allocated between the transferor and the transferee proportionately on the basis of the number of days during the Allocation Period that each was the owner of record of the Units transferred unless the General Partner, as the tax matters partner, after notice to the transferor and transferee, determines that such allocation shall be done as if the Partnership's Allocation Period had ended on the last day of he month immediately following such date of such transfer. Distributions of Partnership assets in respect of Units shall be made only to Persons who, according to the books and records of the Partnership, are the owners of record of the Units in respect of which such distributions are made, on the date determined by the General Partner as of which owners of Units are entitled to such distnbutions. Neither the General Partner nor the Partnership shall incur any liability for making distributions in accordance with the provisions of the preceding sentence, whether or not the General Partner or the Partnership has knowledge or notice of any transfer of ownership of any Units. 8.4 Amortization of Organization and Offering Expenses. In accordance with Section 709(b) of the Code, the Partnership shall elect for federal income tax purposes to amortize its organizational expenses (as this term is defined in that Section) over a penod of 60 months. 79