The Bruce-Stevie partnership was formed to own and operate an apartment project on E Street. Because of local usury laws, it was necessary that T. Joad Enterprises (a corporation owned by unrelated persons) be utilized to hold legal title to the property as a “nominee” (or straw person) for the bene?t of the partnership. Does the Bruce-Stevie partnership A-B want T. Joad Enterprises to be treated as the owner of the project for federal income tax purposes, and, if not, will the partnership get the result it wants? Would the answer be different if the partners of the Bruce-Stevie partnership owned all the stock of the corporation?