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 section 168 cost recovery deductions will be allocated 99% to E until he has been allocated income equal to his share of cost recovery deductions and partnership losses. Thereafter E and F will share income and loss equally. Assuming the capital account, liquidating distribution, and deficit restoration test are met, will the allocation be respected?