Many corporations fail to file timely S elections. Some of these corporations seek relief at the Service Center level, whereas other apply to the National Office of the IRS. Give a brief explanation of the differences between the two venues, or state that there are no substantive differences.

1. Need for a statement of reasonable cause for the lateness.
2. Payment of a user fee.
3. Need for consistency of reporting by corporation and shareholders.
4. Three years and 75 days after intended effective date have elapsed.

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