OPINION
PER CURIAM:
The plaintiffs seek refunds of income taxes and assessed interest totalling $87,636.90, plus interest for calendar years 1965, 1968, 1969, and 1971. The claims arise from two separate sets of facts: (I) the development and construction of a hotel project in Irvine, California; and (II) the purchase and use of two condominium units located on the island of Maui, Hawaii.
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