Fun with controlled groups

[seatpa]

I *think* I have the correct answer to this one, but I thought I'd put it out there for others' input. I may bring in an ERISA attorney for a final determination, if I can talk the business owners into spending the money (they are a bit tight fisted).

We have two individuals, Frank and Joe. Frank and Joe are financial advisors.

Frank 100% owns Frank LLC.

Joe 100% owns Joe LLC.

Frank LLC and Joe LLC each own 50% of S-Corp financial advisory firm ABC. The bulk of Frank and Joe's business and income come from ABC. I have no doubt that this is an ASG.

Frank LLC also owns 100% of another S-corp firm XYZ. Frank LLC and XYZ are obviously a controlled group. However, ABC and XYZ have no real business relationship.

Joe LLC also owns 80% of another S-corp firm, LMNOP. Most of LMNOP's clients are also clients of Joe LLC/ABC. LMNOP performs a different type of busines service from ABC, but Joe LLC/ABC often tries to sell LMNOP's services to its clients. LMNOP and ABC do not perform services for each other or collect any revenue from each other.

The groups here are:

Joe LLC and LMNOP are a controlled group.

Frank LLC and XYZ are a controlled group.

Joe LLC, Frank LLC and ABC are an affiliated service group.

Thoughts?