My problem is whether a "Not-for Profit Firm" (501©) can create or be part of a controlled group.
Basically, there are 3 firms. Firm A is 100% owned by husband and Firm B is 100% owned by wife. They satisfy the exemption for attribution under IRC 1563, so there is no controlled group between A & B.
Firm C is a Not for Profit, and the 2 directors are the husband and wife. Does this create a controlled group for either Firm A or Firm B, or all 3?