The United States Court of Appeals for the Fourth Circuit recently has upheld the Treasury Regulations' expansive definition of a brother-sister controlled group. The author views this decision in light of the history and purpose of the sections of the Code and regulations which it construes. He concludes that the court of appeals' construction is much broader than that intended by Congress, and that legislative clarification is necessary.
Fairfax Auto Parts, Inc. v. Commissioner: Definitional Requirements of the Multiple Corporation for Purposes of Exclusion from Surtax Exemptions,
32 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol32/iss2/9