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Is the following a controlled group?
Rev. 01/11/08, E-mail Alert 2008-1

Scenario: Dad, Mom and two daughters, each over age 21.

Company A: Dad owns 100%.

Company B: Dad owns 30%, Mom owns 30%, Daughter 1 owns 20%, Daughter 2 owns 20%.

Dad receives attribution from Mom so that Dad owns 60%. Dad also receives attribution from daughters 1 and 2 as Dad has 60% (more than 50%). Thus, Dad has 100% through family attribution rules and Company A and B are a controlled group.

 

 

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