this paragraph. (2) Exempt fuel For purposes of paragraph (1), there shall not be taken into account fuel held by any person which is exempt from the tax imposed by subsection (a) by reason of subsection (d) or (e). (3) Controlled groups For purposes of this section— (A) Corporations (i) In general All persons treated as a controlled group shall be treated as 1 person. (ii) Controlled group The term controlled group has the meaning given to such term by subsection (a) of section 1563 of such Code