The regulations allow a corporation to make an irrevocable election to allocate income and expenses

as if the corporation's tax year consisted of two years when a occurs corporate tax year.

a)  Shareholder disposition of 10% of the corporation stock in any 30-day period

b)  Corporation issuance of 15% of the outstanding corporate stock to one shareholder

c)  Shareholder disposition of 20% of the outstanding stock in a 90-day period

d)  Qualifying disposition