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Gary Lesser
Two LLC's are owned as follows by W, X, Y, and Z (all unrelated adults). Are they a brother-sister controlled group?

Since Y and Z have no interest in LLC-B, it wd appear that the more than 50% rule is not met and they are not controlled under Section 1563. Does anyone agree or disagree?

Individuals.....................LLC-A.................LLC-B

W .......................................25%.................. 50%
X .......................................25%.................. 50%
Y .......................................25%
Z .......................................25%
Appleby
I agree- but from a different perspective.

The 50 % rule (effective control) has been met ( W and X)

But the 80% rule ( controlling interest ) has not been met.

Therefore… no brother-sister controlled group exists.
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