Affiliated Service Group? Regularly peforming services or regularly associated?

[Floridaattorney]

Ten unrelated engineers own equal shares in a partnership A that provides engineering and architecture services. These ten people also own equal shares in partnership B that provides building inspection services for lenders and purchasers.

The engineers primarily spend their time working for A and are paid by A for those services. However, they also do building inspections for B and, are paid by B for those services. The partnerships have separate management, separate offices and are otherwise separated.

They are not a control group because the 80% test is not met. However, could they be deemed to be an A affiliated service group? They would meet the ownership test by attribution(414)(m)(2)(a)(i). However, partnership A itself is not providing services to B or, regularly involved in providing services to B. It is the owners who provide the services.

414(m)(2)(a)(ii) requires that the organization be providing services.

That said, there doesnt appear to be any other authority which explicitly confirms that-although the statute would control of course.

Has anyone reviewed this or found any authority which specifically addresses whether this would be an ASG?