In 2016, Tom Morello established an S Corporation, RATM, to purchase a small apartment building in Cocoa Beach, FL. Tom borrowed $500,000 and contributed the same to RATM as a loan. From 2016 to 2018, RATM entered into a number of transactions with other entities in which Tom held an interest (collectively, the RATM Affiliates). Most of the transactions were RATM Affiliates advancing money on behalf of RATM and RATM only partially repaying those advances. These were repeatedly classified as accounts payable on RATM’s books and accounts receivable on the books of the RATM Affiliates. At the end of each year, RATM always had a net payable to the RATM Affiliates. In 2019, the bank foreclosed on RATM and Tom’s investment in RATM became worthless. RATM allocated a loss of $1.3 million to Tom on his 2019 Schedule K-1. At that time, Tom’s $500,000 loan to RATM was still outstanding along with a small amount of interest that was due on that loan. At the time of the bankruptcy, RATM owed the RATM Affiliates $600,000 of accounts payable, of which $300,000 is attributable to Tom as a function of his ownership in the various RATM Affiliates (Tom is not the sole owner of all of the RATM Affiliates). Tom has no other basis in RATM. Tom has a debt agreement with RATM for the initial loan of $500,000 but no such agreements for the loans that were channeled through the RATM Affiliates. The RATM Affiliates advances to RATM were recorded as intercompany payables. Lastly, RATM’s activities are not passive with respect to Tom. Assuming the overall business loss limitations under § 461(l) does not apply, what amount of $1.3 million loss is deductible by Tom?