Assume a client requests you explain in writing to its Board of Directors the potential benefits and problems of electing to be taxed pursuant to Subchapter S of the Internal Revenue Code. Prepare a letter to the Board in not less than 1,000 nor more than 2,000 words. The letter should include how and when the election can be made, the effect on the tax liabilities of both the corporations and its shareholders, and a comparison with partnership taxation.