G-81.) Richie is a wealthy rancher in Texas. He operates his ranch through a grantor trust set up by his grandparents. Richie does not like to get his hands dirty, so he hires a professional management company to run the ranch. The property generated a $500,000 loss this year. Can Richie deduct this loss on his Schedule E given the material-participation rules of IRC 469? You will be required to post a Memo to Client File for General Research.

Please provide a the Memo to Client File with good explanation.

Thanks