A Corporation Whose Only Shareholder is a Roth-IRA is Ineligible to Make a Subchapter 'S' Election

In this case, the United States Ninth Circuit Court of Appeals held: A corporation whose sole shareholder is a custodial Roth Individual Retirement Account (Roth IRA) is ineligible to make a Subpchapter 'S' Election under Section 1361 of the Internal Revenue Code.
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