controlled group
(2) Controlled group For purposes of this subsection, the term “controlled group” means a controlled group of corporations (as defined in section 1563(a) ); except that— (A) “more than 50 percent” shall be substituted for “at least 80 percent” each place it appears, (B) the ownership requirements of section 1563(a) must be met both with respect to voting power and value, and (C) the determination shall be made without regard to subsection (a)(4) of section 1563.