A and B are equal partners in AB partnership. The partnership agreement provides that capital accounts will be maintained in accordance with the Regulations and liquidating distributions will be made in accordance with capital account balances. The partnership agreement also gives both A and B an unlimited deficit restoration obligation. Generally A and B are in the same marginal tax bracket. All income and losses are allocated equally to A and B. A has a net operating loss from another venture that will expire in the partnership's second tax year. The partnership agreement is amended at the beginning of the second tax year to provide that all of the partnership's net taxable income will be allocated to A for that year. Thereafter, net taxable income for that year is to be allocated to B until B's allocation equals the allocation in the second tax year to A, after which the partnership will revert to 50-50 allocations. Describe the tax consequences.