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I believe that for purposes of qualified plans, in determining whether or not a brother sister control group exists, the shareholders of the two or more organizations being analyzed need to be individuals, defined as individuals, trusts or estates.

If the direct sharholders are partnerships, not individuals, does the inquiry stop there.

Or do you look to see who the owners of the partnerships are and attribute ownership through the partnership to them and see if a brother sister controlled group exists through organizational attributions.

Thanks

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