Mike contributed $50,000 in exchange for a general partnership interest and Ned contributed $50,000 in exchange for a limited partnership interest. The partnership agreement provides that Mike and Ned share profits and losses equally, but that depreciation will be allocated to Ned in the first year and to Mike in the second year of the partnership. The agreement satisfies the rules for economic effect under the alternative test. At the time the agreement is drafted Mike has net operating losses that will expire at the end of the first year from another business venture he's involved with. Ned has no such losses. Will the special allocation of depreciation be respected?