Reba and Jimmy contribute $180 and $20, respectively, to their newly formed partnership. The partnership borrows $800 on a nonrecourse basis from an unrelated third party and purchases a depreciable building for $1,000. The building secures the repayment of the $800 nonrecourse debt. No principal payments are payable with respect to the $800 nonrecourse debt until after ten years. The building is depreciable on a straight line basis over ten years. Reba and Jimmy agree to allocate losses 90%/10%, respectively, and agree to allocate income first to restore all previously allocated losses and then 50% to each partner. Nonrecourse deductions are to be allocated 50% to each partner. Distributions are made first to return capital to the partners, then 50% to each partner. Assume that the requirements in Treas. Reg. Sec. 1.704-2(e) are satisfied and that all the partnership's income is used to pay expenses (i.e., the net loss of the partnership each year equals the depreciation expense of the partnership).\