I would walk very carefully down this path. Any allocation other than based on the partners interest in the partnership (known as PIP) must have substantial economic effect (SEE). The regulations that cover this area are voluminous and understood by very few.
While CA may allow for an oral partnership agreement, that doesn't mean anything to the IRS. As stated above, unless you have a special allocation drafted in your partnership agreement, and can prove to the IRS that the special allocation meets the SEE test, the IRS will use the default PIP allocation.
Additionally, your reasoning of building up more equivalent amounts in the tax deferred retirement accounts does not sound like it would pass the substantial economic effect test.
I believe you are playing roulette here and would not prevail if audited.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
