Prepare a tax research memorandom with respect to the following
A potential new client, John, is the owner of a three-bedroom cabin in Maine. During this past year, he contracted with a property management company to rent the cabin to third parties. In exchange, John paid the company a 35% commission on all rental income received. The property management company was responsible for maintaining the property. The cabin was rented three times during the year for a total of 12 days and nine nights with the average rental period being three days. John visited the cabin eight times during the year and stayed 19 nights and 27 days. John claimed $20,000 of Schedule E expenses relating to the rental of the cabin on his return under the active rental real estate exception. Was John entitled to the deduction? State any assumptions made.