JOHNSEN, Circuit Judge.
The Board of Tax Appeals redetermined income tax deficiencies against petitioner for the years 1934, 1935 and 1936, on the rents which the corporation had collected from a piece of real estate to which it held the record title, and petitioner seeks to reverse the Board's decision on the ground that the corporation's title to the property was purely nominal and that it was simply serving as a conduit for the payment of the rents to its stockholders...
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