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44 Probate & ProPerty j September/OctOber 2009 common control within the meaning of subsections (a) or (b) of Code § 52. Code § 101(j)(3)(B). In general, these sections refer to relationships among family members, shareholders and corporations, corporations that are members of a controlled group, trust grantors and fiduciaries, tax-exempt organizations and the persons who control them, estates and beneficiaries, commonly controlled S corporations, partnerships, and C corporations, commoonl...