controlled group

I just want to confirm...

I have 3 companies

Father owns 100% of company A & B

Daughter (over age 21)  owns 51% of company C and Father owns 49% of company C

A & B are controlled

C is not controlled.

I appreciate your help!

Thank you !

Agree, subject to the normal caveats about option attribution, separate stock classes, etc., etc.

Thank you.

I agree that Company "C" is not "controlled" by Father. You were looking at this from a strictly control perspective and not as it related to IRC 4975. 

I thought that if the Parent owned more than 50% of the stock then their shares were attributed to an adult child.  

No - if the parent owns >50%, then the adult child's ownership is attributed to the PARENT. If the adult child's ownership is >50%, then the parent's ownership is attributed to the adult CHILD. This is for Section 1563 attribution. Very different under Section 318 attribution.