controlled group of corporations

[lexi]

can anyone lend me insight re the following:

Corp A= john 25 %; pam 37%; and mary 38%

Corp B= john 15; pam 15; mary 15; joe 55

Corp C= john 33.3; pam 33.3; and mary 33.3

when applying section 1563's brother-sister controlled group analysis, do you apply the test on a one-on-one basis or as a group?

for example: would you look at corp A and corp B. corp A and corp C

and then corp B and corp A. corp B and corp C.

and then corp c and A. corp C and B?

OR

do you look at all three together and see if the 50-80% tests apply to them as a group of three companies?

thanks in advance for your help.

[R. Butler]

You do need to look at individual company in relation to every company on a one-to-one basis.

For example in your facts A & C are part of a controlled group irregardless of whether B is part of that group.