Jennifer Woods is 32 years old and for the last six years has been employedas a manager by Ski USA, a distributor of ski equipment and boots. In thepast two years as a professional bicycle racer she has participated inapproximately 50 races annually. Although she has won some of them,Jennifer has incurred annual expenses that far exceed her annual incomefrom racing. Jennifer trains extensively on a daily basis; she has sponsorswho have provided her with the bicycles, clothing, and occasionally, entry fees required for participation in these races. Otherwise she pays her ownexpenses which include the costs of bicycle repairs, transportation, lodging,and most entry fees. During racing season, she works a lighter schedule at Ski USA and also utilizes her vacation time. The National Bike Racing Association ranked Jennifer in two events - the dual slalom and downhillraces - for which she wears a full-face helmet, chest protector, kneeprotection, elbow pads, goggles, and heavy duty clothing.Jennifer wants to know if she was correct in deducting her expenses as adeduction for AGI against the winnings from races in which she has wonprize money and the sponsorship income she has received.Submit a brief memorandum addressed to Jennifer, in which you report yourfindings. Identify any relevant statutory, regulatory, and judicial authorities.