Memorandum Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies of $9,002 and $4,050 for Brookhaven Residential Sales, Inc. (Brookhaven), and Sterling Homes, Inc. (Sterling), respectively, for the taxable year ended December 31, 1976. The only issue for decision is whether Brookhaven and Sterling (petitioners) are component members of a brother-sister controlled
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