QSLOB-Requirement of administrative scrutiny

[Guest chiphop]

My question relates to two members of a controlled group. Each is an incorporated entity that should each meet the QSLOB rules, except for perhaps the requirement for administrative scrutiny. Under the administrative scrutiny rules and the safe harbor relating to each of the SLOBs being in a different line of business, one entity is in Group 30 and the other is in Group 51 (relating to their SIC codes). In Revenue Procedure 91-46, where the IRS lists the different industry categories, Group 51 and Group 30 are NOT in the same category. However, Group 51 appears no where in the Rev Proc...so that concerns me. I am considering a request for an individual determination from the Commissioner that the separate line of business satisfies the requirement of administrative scrutiny but it is so expensive....anyone have something like this happen to them and how did you proceed?