Research Memo

It is nearing the end of the year and your client, Amy Smith, approaches you about the treatment of the income and losses she will earn from her nonrental activities this year. She provides you with information for each activity including the total number of hours she has spent to date and the total projected income or loss from each activity. No other individual has worked more than Amy in any of these activities.

Activity Hours	Worked	Projected Income (Loss)
1	168	($32,000)
2	92	$42,000
3	180	($13,000)
4	53	($22,000)
5	104	$18,000
6	98	$26,000

Draft a tax research memo to arrive at a conclusion and make a recommendation to Amy, citing appropriate primary authority.

(Hint: focus on IRC Section 469 and the related regulations.)