In Batson v. Strehlow (1968) 68 Cal.2d 662, the court had to deal with the situation in which a sale was confirmed to an ostensible purchaser defendant from the broker. The broker received the commission and the Batson case itself was a lawsuit brought by the estate to recover back the commission which had been paid to the broker. In that action, it was established that the purchaser was in fact solely owned by the broker and his wife. Indeed, it was revealed that immediately after the property was conveyed to the purchaser, San Antonio, it was immediately transferred by San Antonio to a partnership composed of the broker and other associates. In Batson, the court made a finding that the defendant broker had not disclosed to the plaintiff estate or to the probate court that the broker and his wife owned all of San Antonio stock or that the broker and his associates were putting up the entire purchase price to secure the property.