26 U.S.C. § 1363 — Effect of election on corporation

section 617 (relating to deduction and recapture of certain mining exploration expenditures), and

section 901 (relating to taxes of foreign countries and possessions of the United States).

an S corporation was a C corporation for the last taxable year^* before the first taxable year for which the election under section 1362(a) was effective, and

the corporation inventoried goods under the LIFO method for such last taxable year,

Any increase in the tax imposed by this chapter by reason of this subsection shall be payable in 4 equal installments.

The first installment under subparagraph (A) shall be paid on or before the due date (determined without regard to extensions) for the return of the tax imposed by this chapter for the last taxable year for which the corporation was a C corporation and the 3 succeeding installments shall be paid on or before the due date (as so determined) for the corporation’s return for the 3 succeeding taxable years.

Notwithstanding section 6601(b), for purposes of section 6601, the date prescribed for the payment of each installment under this paragraph shall be determined under this paragraph.

the inventory amount of the inventory asset under the first-in, first-out method authorized by section 471, exceeds

the inventory amount of such assets under the LIFO method.

The term “LIFO method” means the method authorized by section 472.

The term “inventory assets” means stock^* in trade of the corporation, or other property of a kind which would properly be included in the inventory of the corporation if on hand at the close of the taxable year.

The inventory amount of assets under a method authorized by section 471 shall be determined—

Except as provided in regulations, the corporation referred to in paragraph (1) shall not be treated as a member of an affiliated group with respect to the amount included in gross income under paragraph (1).