T.C. Memo. 2000-67
UNITED STATES TAX COURT
CHICAGO MERCANTILE EXCHANGE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8984-95, 16082-95. Filed March 2, 2000.
P is a not-for-profit corporation that operates a
commodity exchange in Chicago, Illinois. R argues that
P has no affiliates within the meaning of sec.
204(a)(7)(C) of the Tax Reform Act of 1986 (TRA), Pub.
L. 99-514, 100 Stat. 2085, 2155, because P is not a
member of a controlled group of corporations. R
asserts that the flush language of TRA sec. 204(a)(7),
which provides that “a corporation is an affiliate of
another corporation if both corporations are members of
a controlled group of corporations”, is the exclusive
definition of the word “affiliates” for purposes of TRA
sec. 204(a)(7).
Held: The flush language on which R relies merely
specifies when a corporation will be considered to be
an “affiliate” of another corporation; it does not
contain the exclusive definition of that word for
purposes of TRA sec. 204(a)(7).
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