On 1/1/12, Sam and Ronny form the SR partnership, with Sam contributing property (“Property S”) with a fair market value of $800 and an adjusted tax basis of $400, and Ronny contributing $800 cash. The SR partnership agreement includes provisions calling for capital accounting in accordance with section 704(b), liquidating distributions in accordance with capital account balances, a qualified income offset provision, and a minimum gain charge back provision, but no deficit restoration provision. The SR partnership, on 1/2/12, purchases Property X, a depreciate building, for $4,000, using $400 of cash contributed by Ronny, and incurring a non recourse note (secured by Property X) in the amount of $3,600. The SR partnership will depreciate the building, using the straight line method, over a 10 year period ($400 per year, including year 1). The SR partnership wishes to allocate the annual $400 depreciation deduction to Ronny for tax purposes. Describe whether the allocation will be respected for the tax years ending 12/31/12 and 12/31/13.
