Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner, in his statutory notice, determined a deficiency of $1,537 in petitioners' Federal income tax for their taxable year 1975. The issue is whether petitioners' operation of their beach cottage (hereinafter the cottage) for that year was an "activity * * * not engaged in for profit" within the meaning of section 183(a), Internal Revenue Code of 1954.
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