LO.3 Gloria Martinez, an NRA, is a professional golfer. She played in seven tournaments in the United States in the current year and earned $250,000 in prizes from these tournaments. She deposited the winnings in a bank account she opened in Mexico City after her first tournament win.

Gloria played a total of 30 tournaments for the year and earned $800,000 in total prize money. She spent 40 days in the United States, 60 days in England, 20 days in Scotland, and the rest of the time in South America. Write a letter to Gloria explaining how much U.S.-source income she will generate, if any, from her participation in these tournaments and whether any of her winnings are subject to U.S. taxation. Glorias address is AV Rio Branco, 149-4#, Rio de Janeiro, RJ 20180, Brazil.