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 $500,000loss this year Can Richie deduct this loss on his Schedule E given the Material-participation rules of IRC section 469.

G-97. Dean and Robin owned a family business, each holding the shares as community property. When they were divorce in 2017, the court did not force them to split the shares, citing damage to the business that could occur if the public learned that ownership of the enterprise was changing. Now it is 2020, and Robin wants to remarry. She and her new husband want to have the business retitle one-half of shares in Robins name only. The original divorce court agrees in 2020 Is this transfer subject to income tax? Is it subject to gift tax?