"Write a memorandum to your client Dr. Green addressing each of the issues listed below. The memorandum should be no less than one page and no more than three pages in length. 
APPLICABLE LAW 
This assignment is primarily designed to expose students to common sources of tax law (court opinions, regulations, etc.) and how to apply them to fact patterns. This is not a research paper, although students who wish to do their own research are welcome to do so (but it's not required). All the legal sources required to address the issues presented are provided in Doc Sharing: (a) the Whitten case, (b) the Rusnak case, and (c) Treasury regulation 1.165-10. Use these sources of tax law to formulate your advice regarding each of the issues listed below:

ISSUES

1. Dr. Green is a practicing physician in Chicago who, as an avid blackjack and slot machine player, travels to Las Vegas every other weekend to gamble. He would like to know what criteria are used to determine whether his gambling activities constitute a trade or business for federal income tax purposes and whether or not you think his gambling activities qualify for trade or business status.

2. If Dr. Green's gambling activities do not qualify as a trade or business, can he deduct his gambling-related travel and lodging expenses against his gambling winnings?

3. Assume Dr. Green's wife, Mrs. Green, gambles to the same extent that Dr. Green gambles. Assume that the Greens file a joint tax return. If Mrs. Green has a large net gambling gain for the year and Dr. Green has a large net gambling loss, can they combine their gambling transactions and use his loss to offset her winnings?