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Showing results for tags 'Has it been enforced?'.
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I have been looking at some articles lately, including examples provided by McKay Hochman, Derrin Watson and others that talk about the spousal exception (relating to attribution under the controlled group rules) not being applicable when the couple has a minor child because ownership is attributed to the child and that messes everything up. There are comments about that being the letter of the law, but not necessarily the intention. I have to believe that there must be a pretty large number of couples where each spouse owns his/her own (separate) business and they have at least one child. However, I haven't seen any write-ups about the controlled group status being enforced, and I'm pretty sure it's not because they are following the rules (yes, I'm a cynic). Has anyone heard the IRS make any informal comments about this, or has anyone seen it enforced? Or is this one of those things that's quietly swept under the rug and nobody talks about it?