Betsy Babington participated in the Great British Bake Off and won first prize, after which she became a

celebrity baker, the most famous in the world. She moved to the U$.$S$.,$ became a U$.$S$.$ citizen, and then

used her celebrity status to start her own bakery called British Babington$$s Bakery in downtown Fairfax,

VA where she makes tasty treats for local Brits and non$-$British GMU students who just want a delicious

piece of heaven after their grueling tax class is finally over. She operates her bakery as an LLC and

includes her $$1,000,000$ bakery income on her personal tax return as income from a disregarded entity.

In addition to her bakery income, Betsy receives large endorsement fees of $$500,000$ due to her skill and

reputation as a baker. These fees are for the use of her name on a line of cooking utensils and cookware.

She was ecstatic when she heard about TCJA$$s Qualified Business Income Deduction of $20\%!!!$ However,

her excitement was short lived because she knows the principal reason her business thrives is because

of her reputation as a celebrity on the British Baking Show. She heard that high$-$paid celebrities are

disqualified from taking the QBI deduction because they are categorized as a Specified Service Trade or

Business $($SSTB$).$

She has come to you and asked whether her just her $$1,000,000$ bakery income is an SSTB$,$ just her

$$500,000$ endorsement income is an SSTB$,$ or the entire $$1,500,000$ is an SSTB$.$

Take a position on this Question: Which of Betsy$$s income meets the definition of Specified Service

Trade or Business, $1)$ just the $$1,000,000$ bakery income, $2)$ just the $$500,000$ endorsement income, or

$3)$ the entire $$1,500,000$ income?

Primary Authority: State the Primary Authority supporting your conclusion.

Your Logic Supporting your Conclusion: State the logic you used in coming up with your conclusion, be

sure to show you put thoughtful consideration into determining your position.