Chicago Mercantile Exchange - Page 1

                                 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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