Anne White, a client who lives in Richmond, has owned a second property in Wintergreen for three years. Each year, the taxpayer rents the property during the winter months (December through March) and uses the property for personal reasons for the entire month of July. However, for two of those three years, her daughter Ellen lived in the property for those three months, paying less than the fair rental. For the remainder of the year, rentals are sporadic, usually totaling about 100 days.

Write a memo that provide two tax codes, regulations, cases, and other primary authorities that could be used to answer this situation.