Note:
Joseph A. Snoe, Brother-Sister Controlled Groups: The Basic Eighty Percent Stock Ownership as Control. 58 Texas L. Rev. 1161 (1980).
 

Abstract:
This Note argues that the “Eighty Percent Test” imposed by Section 1563 of the Tax Reform Act of 1969 is the only test necessary to determine which corporations are brother-sister corporations. The Note traces the development of that section and presents a summary of judicial review.