On January $1,$ year $1$ Maria borrows $$70,000$ from a commercial bank and uses the loan proceeds, together with $$30,000$ of her own funds to purchase the food in souvenir concession at a local ballpark. the loan is non$-$recourse. in year $1$ the concessions has a taxable loss of $$40,000.$ in year $2,$ the concession has taxable income from operations of $$25,000.$ maria does not contribute or withdraw any funds from the operating in year $1$ or year $2.$ maria materially participates in the activity during both years