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?

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Please include the following accounting specifics:

Code Section

Accompanying Regulation

Rev. Rul.

Rev. Proc.

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