OPINION
BRUCE, Judge:
Respondent determined a deficiency in the income tax of the Butters Realty Co. for the year 1960 in the amount of $283.35. The sole issue is whether rental payments made by a sublessee to a third party are income to the sublessor.
All of the facts have been stipulated and the stipulation of facts and exhibits attached thereto are found accordingly.
The petitioner is a nonprofit corporation organized and existing...
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