Controlled Groups and S Corp.s

[Guest LLandau]

Help.

Separate (both subchapter S Corp.s) companies are 100% owned by only two non-spouse individuals. Information provided to me is that together these two individuals own 100% of both companies.

Question: Because these are S Corp.s is it even possible that the two companies are of the same Controlled Group of Companies?

My confusion is that because of the nature of S Corps. Mr. A and Ms. B each own some percentage of each company (and are bro-sis co.s), but unless A and B form a holding co. they do not each/together own 100% of the corp.s as set forth in IRC Section 1563.

The individuals (A and B) insist that together they own 100% and, therefore, the companies are within the same controlled group of companies.

Any guidance would be appreciated.