G and L form a limited partnership. G, the general partner, contributes $80,000 and L, the limited partner, contributes $320,000. The partnership purchases commercial real estate on leased land, paying $400,000 cash and borrowing $1,600,000 on a nonrecourse basis from a commercial lender. The terms of the loan require payment of interest only for the first five years. The GL partnership agreement allocates all income, gain, loss and deductions 20% to G and 80% to L until the first time that the partnership has recognized items of income and gain that exceeded the items of loss and deduction recognized over its life , and then all further partnership items are to be allocated equally between G and L. At the time the partnership agreement is entered into, there is a reasonable likelihood that, over the partnership’s life, it will recognize amounts of income and gain significantly in excess of losses and deductions. The partnership agreement requires that all allocations are to be refle