EVANS, Circuit Judge.
Petitioners reported taxable income for the years 1925, 1926, and 1927. The correctness of the taxes assessed thereon is the only question presented to us. Respondent contends that the Zenith Real Estate Trust was taxable as a corporation. Petitioners, on the other hand, argue that it should have been taxed at the rate the revenue acts provided for the taxation of a trust. Two small items, penalties for the years 1925 and 1926, amounting to ...
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