Controlled Group?

[Zoey]

I am starting to question myself on whether this is a controlled group due to stock attribution.  I don't think it is and would appreciate some input from others...

Two companies.  The ownership for Company A is 100% Joe.  The ownership for Company B is 25% direct ownership Joe, 25% direct ownership Jane (spouse of Joe), 50% direct ownership Tom (father of Jane).  Since Jane and Tom are not employees of Company A (and have nothing to do with Company A), they would not be considered an owner of Company A (since there is no direct ownership, income, voting rights, etc.), correct?  So then it comes down to just Joe's determination.  Since Joe owns 100% of Company A and 25% of Company B, and taking into account that even with Jane's 25% direct ownership, that would mean that due to stock attribution, they own 50% of company B, correct?  Tom is also employed by Company B.  His direct ownership is 50%.  So when it comes down to identical ownership, it is right at 50%, correct?  But my understanding is that they have to have MORE THAN 50% direct ownership to be considered.   Do you agree that this would not be a controlled group?  

Thank you in advance, for your responses.

[RatherBeGolfing]

It is not a controlled group.  Since Joe is 100% owner of A, we look at Joe's ownership in B.  We need 80% common ownership to be a controlled group.  We do not.  Had we had 80%, we would have moved on to see if we also have 50% identical ownership, but we don't have to take that step.

[Zoey]

Thank you for your response!  I didn't think it was a controlled group either, but with all of the stock attribution, I was questioning myself on how much each one was "considered" to own.

[RatherBeGolfing]

You are welcome :)