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  1. Griswold
    If a company wants to convert from an S to a C so that the owner/seller can make a 1042 election, will the owner have to then wait three years to meet that holding requirement of 1042? Or does their ownership of the S stock (assuming for three years) tack over? I could have sworn that the ownership "tacks" but I can't find much support out there. If anyone has some support, I would appreciate it. Thanks!
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