I have read 215(b) and am still not sure how to treat an executive officer who along with his wife owns 50% of a partnership. Mr. X owns the other 50%.

Since ownership of the partnership is equal, it would seem my executive officer does not have majority ownership and I would not have to worry about Reg O. This does not seem right!!

Please, I would be interested in hearing how others are addressing similiar situations. Thanks --

Look at 215.2(c)(1) - he owns more than 25% of the company and therefore it is assumed he has "control" and therefore it is a related interest.

I found it. Thank you so much.