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). 1 Because of this classification as brother and sister corporations, the three corporations were entitled to only one surtax exemption between the three of them. This limitation increased the amount of total taxable income of…