OPINION
BOWNES, District Judge.
Plaintiffs bring this action to recover federal income taxes and interest, in the amount of $1,072, which they allege were erroneously or illegally assessed and collected. Jurisdiction is based on 28 U.S.C. § 1346(a)(1).
The issue is whether plaintiffs, who ceased to use their summer house as residential property in 1967 and immediately offered it for sale without attempting to rent the property, converted it...
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