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Hastings Law Journal

Abstract

A brother-sister controlled group exists where the stock of two or more corporations is held in sufficient quantity by the same small group of shareholders such that the corporations can be operated as a single unit. The controlled group is then taxed as a single corporation. This Comment argues that the current definition of a controlled group found in I.R.C. § 1563(a)(2) is overinclusive in some respects, and underinclusive in others. The Comment discusses the problems raised by the current statute, and concludes with a proposal for a new statute aimed at resolving these deficiencies.

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