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shareholder. We conclude that petitioner’s members were not its
affiliates for purposes of TRA section 204(a)(7).2
Even if petitioner’s members were its affiliates for
purposes of TRA section 204(a)(7), petitioner would have failed
the second requirement; to wit, that the leased building serve as
the world headquarters of it and each of its affiliates.
Although the CME Center arguably served as petitioner’s “world
headquarters” in the sense that petitioner had offices and
employees located throughout the world, see Payless Cashways v.
Commissioner, supra, petitioner has not established that the CME
Center also served as the world headquarters of its approximately
2,700 members. Approximately 1/4 of those members are
corporations and the remainder are individuals. Under the
holding of the Court of Appeals for the Seventh Circuit in United
States v. Kjellstrom, supra, a corporation does not qualify for
the world headquarters exception merely by virtue of the fact
that the corporation is owned by individuals and has more than
one office.
2 Nor do we believe that petitioner was an affiliate of
either CCP or PMT for purposes of sec. 204(a)(7) of the TRA, Pub.
L. 99-514, 100 Stat. 2146. Petitioner looks solely to its 10-
percent ownership interest in each partnership and concludes from
this bare fact that it and the partnerships are affiliates. We
disagree. None of the shareholders in United States v.
Kjellstrom, supra, were considered by the Court of Appeals for
the Seventh Circuit to be Wisco’s affiliate, and the interest of
at least one of those shareholders was at least 16.6 percent.
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