Donald Dudley and Webster Dudley are local real estate developers. (a) A corporation might obtain the land and some period of time may elapse between the acquisition and the commencement of construction. To minimize carrying costs, after the acquisition but prior to transferring title of the land to Dudley Brothers Construction Company upon commencement of construction, the corporation will lease out the vacant land. For example, rural land may be rented out for farming and city land may be rented out to another company to run a parking lot. The nominee corporation would simply receive rents, deposit checks to a bank account, and immediately pay the rent over to Dudley Brothers Construction Company using its own checks. 

Question: Will the activities be taxed to the corporations or will the corporation be ignored for tax purposes? (b) One or more of the corporations would acquire fee simple title and/or options on the land in its own name, and upon completing the acquisition would immediately transfer title to the land and/or the options to the partnership. Question: Will the activities be taxed to the corporations or will the corporation be ignored for tax purposes?