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bulletin Internal Revenue›Rev. Proc. 90-63, 1990-2 C.B. 664, is

SECTION 3. SCOPE

Internal Revenue Bulletin 1997-33 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure provides a special procedure to request relief for a late S corporation election. This revenue procedure applies only to a corporation (1) that has not filed a timely S corporation election under § 1362(a)(1), and (2) for which an S corporation election is filed within 6 months of the original due date for the election. This revenue procedure does not provide relief for late shareholder elections including a qualified subchapter S trust (QSST) election or electing small business trust (ESBT) election. This special procedure is in lieu of the letter ruling procedure that is used to obtain relief for a late S corporation election under § 1362(b)(5). Accordingly, user fees do not apply to corrective action under this revenue procedure. A corporation that is not eligible for relief under this revenue procedure, or is denied

relief, may request relief by applying for a private letter ruling. The procedural requirements for requesting a private letter ruling are described in Rev. Proc. 97–1, 1997–1 I.R.B. 11 (or its successor).

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▸Contents — Internal Revenue Bulletin 1997-33
Internal Revenue Bulletin 1997-33

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