Required Tax Return Positions

Required Tax Return Positions. Mean the positions that for U.S. federal income Tax purposes (i) the Common Stock purchased by each Indemnitee constitutes property transferred to such Indemnitee in connection with the performance of services pursuant to Section 83(a) of the Code and (ii) the price paid by each Indemnitee for the Common Stock purchased pursuant to the Subscription Agreement was equal to the fair market value of the Common Stock on the date of purchase and, accordingly, each Indemnitee is not required to... recognize any income or gain in connection with the filing by such Indemnitee of an election under Section 83(b) of the Code. Any one of the above positions shall be referred to herein as a "Required Tax Return Position." View More