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On brief, the parties proceed on the assumption that section
1504(a) applies not only for 1984 but also for 1985 and 1986 and
that amended section 1504(a) does not apply for 1985 and 1986.
Consequently, they make no argument, and presumably they did not
present all the evidence that they might have, with respect to
the 80-percent value test in amended section 1504(a)(1)(B) and
(2)(B). While we agree that section 1504(a) is applicable for
1984, we disagree that that section applies for 1985 and 1986.
That is because we find below that for 1984 petitioners were not
members of the affiliated group within the meaning of section
1504(a) that had Amax as its common parent. Accordingly, the
special effective date rule does not apply, and the question
whether for 1985 and 1986 petitioners were members of the affili-
ated group that had Amax as its common parent must be resolved
under amended section 1504(a).
Since the parties address for each of the years 1984, 1985,
and 1986 only the 80-percent voting power test of section 1504(a)
before its amendment by the 1984 Act, and since that test, as
pertinent here, is essentially the same as the 80-percent voting
power test of section 1504(a) after its amendment by the 1984
Act, compare sec. 1504(a) with amended sec. 1504(a)(1)(B) and
(2)(A), we generally shall do the same. However, we are in no
way suggesting that that is the only test that petitioners must
satisfy for 1985 and 1986 in order to be members of the affili-
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