$2.$ On January $1,2022,$ G and L formed a limited partnership to acquire and operate a rental apartment building. L$,$ the limited partner, contributed $$135$ and G$,$ the general partner, contributed $$15.$ The partnership obtained a nonrecourse loan from an unrelated financial institution for $$850$ and purchased a building for $$1,000$ on leased land. The loan is secured by the building. The loan requires interest to be paid currently, but does not require any principal payments for $25$ years. The building is depreciable over $10$ years at the rate of $$100$ per year.

The partnership agreement satisfies the first two requirements of the basic test for economic effect $($i$.$e$.,$ the capital account and liquidation requirements$).$ L has no obligation to make up any deficit in her capital accoun