I told Caleb by e$-$mail that, after an election has been terminated,

must pass before a new election can be made. Theoretically, Caleb must wait until

before a new election is available. Code $1362($f$)$ allows the IRS to make exceptions to this rule and permits an earlier election in the following two situations.

There is a

change in ownership

the first year for which the termination is applicable.

The event causing the termination

reasonably within the control of the S corporation or its majority shareholders.

Thus, Caleb may have a chance of

$.$