Savannah is the owner of a three-bedroom cabin in Georgia. During 2020, she contracted with a property-management company to rent the cabin to third parties. In exchange for its services, Savannah paid the company a 35% commission on all rental income received. The property-management company was responsible for maintaining the property, cleaning the cabin, paying all utilities, providing linens, and so on. The cabin was rented three times during the year for a total of 12 days and 9 nights, with the average rental period being three days. Savannah visited the cabin eight times during the year and stayed 19 nights and 27 days. Savannah claimed $15,000 of Schedule E expenses relating to the rental of the cabin on her return under the active-rental-real-estate exception. Was Savannah entitled to the deduction? Please be as comprehensive as possible in your answer.

Please prepare a tax memo using the following format:

Section 1 - Facts

Section 2 - Issue(s)

Section 3 Rules

Section 4 - Analysis

Section 5 Conclusion