Scam Co., a very profitable corporation, and Poor Co., a company that has net operating losses to that will last for many years to come, form a partnership as equal partners. Scam Co. contributes an airplane with a $500,000 tax basis and a value of $5 million, and Poor Co. contributes stock of a subsidiary that has a tax basis and value of $5 million. The partners agree to share profits and losses equally. The airplane has one year left in its depreciable life. The partnership elects to use the traditional method of making IRC sec 704 (c) allocations. In its second year, the partnership sells the airplane for $5 million. What are the consequences to the partners for the partnership's first two years?