On 1/1/11, Sam and Ronny form the SR partnership, with Sam contributing property (“Property S”) with a fair market value of $800 and an adjusted tax…

On 1/1/11, Sam and Ronny form the SR partnership, with Sam contributingproperty (“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 includesprovisions calling for capital accounting in accordance with section 704(b),liquidating distributions in accordance with capital account balances, a qualifiedincome offset provision, and a minimum gain chargeback provision, but no deficitrestoration provision. The SR partnership, on 1/2/11, purchases Property X, adepreciable building, for $4,000, using $400 of cash contributed by Ronny, andincurring a nonrecourse note (secured by Property X) in the amount of $3,600. TheSR partnership will depreciate the building, using the straight line method, over a 10year period ($400 per year, including year 1). The SR partnership wishes to allocatethe annual $400 depreciation deduction to Ronny for tax purposes. Describewhether the allocation will be respected for the tax years ending 12/31/11 and12/31/12.

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