On January $1,2022,$ H and N formed a limited partnership to acquire and operate a rental apartment building. N$,$ the limited partner, contributed $$680$ and H$,$ the general partner, contributed $$120.$ The partnership obtained a nonrecourse loan from an unrelated financial institution for $$5,200$ and purchased a building for $$6,000$ 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 $$600$ 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$).$ N has no obligation to make up any deficit in her capital account. The partnership agreement, however, does have a QIO provision. It also has a $$minimum gain chargeback$$ provision as described in $1\mathrm{.}7042($f$).$ The partners agree that nonrecourse deductions will be shared equally. Finally, the agreement provides that all items of income, deduction and loss, other than nonrecourse deductions, will be allocated $85\%$ to N and $15\%$ to H$.$

For the taxable years $20222024,$ the partnership has $$600$ of gross rental income and $$600$ of out of pocket expenses $($$$260$ in interest and $$340$ in operating expenses$).$ As a result of the depreciation deduction on the building, the partnership has an annual net tax loss of $$600$ each year. During this period, the partnership makes no distributions.

The partnership$$s initial balance sheet is as follows:

Assets Liabilities & Capital

Basis$/$Book

Building $$6,000$ Mortgage $$5,200$

Capital Accounts

Tax$/$Book

H $ $120$

N $680$

$$800$

How would the loss be allocated in year $2022,2023$ and $2024.$