E and F form a limited partnership to purchase and lease a computer for $1,000,000. E, the limited partner, contributes $990,000, and F, the general partner, contributes $10,000. The agreement provides that Internal Revenue Code Section 168 cost recovery deductions will be allocated entirely to E, and that all other items of income or loss will be allocated 99% to E until he has been allocated income equal to his share cost of recovery deductions and partnership losses. Thereafter, E and F will share income and loss equally. Assuming the capital account, liquidating distribution, and deficit restoration tests are met, will the allocations be respected? See Reg. Section 1.704-1(b)(5) examples (2) and (3).