Court of Appeals for the Tenth Circuit July 1, 1985, 83-1907 (Complete Finance Corporation, Sandia Auto Electric, Inc., Lomas Warehouse, Inc., New Mexico Corporations v. Commissioner of Internal Revenue)

McKAY, Circuit Judge.

The facts in this case have been stipulated, 80 T.C. 1062 (1983), and the only issues on appeal are questions of interpretation of the Internal Revenue Tax Code. The case involves three New Mexico corporations that were determined by the Commissioner to be brother and sister corporations within the definition found in 26 U.S.C. § 1563(a)(2) (1982).