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ration (Form 1120S), for IAMCM/PRINCIPIA for 1991 and Forms 1120S
for IAMCM for 1993 and 1994. The EIN shown in each of those Forms
1120S was 43-1577193. Petitioners did not prepare or file Forms
1120S for IAMCM/PRINCIPIA or IAMCM for 1992 or 1995.
In April 1997, the agent advised petitioners about the rules
that require the filing of an election on Form 2553, Election by a
Small Business Corporation (Form 2553), in order for a small
business corporation to be treated as an S corporation. No Form
2553 has been filed with respondent on behalf of IAMCM, IAMCM/
PRINCIPIA, or International Academy of Mathematical and Computer
Modelling, Inc.
In the notice, respondent determined, inter alia, to disallow
the S corporation losses claimed in Schedules E of petitioners’
1993, 1994, and 1995 returns because “The election to be treated
as an S corporation (small business corporation) was determined to
be invalid.”
Discussion
Petitioners used the same EIN for International Academy of
Mathematical and Computer Modelling, Inc., IAMCM, and IAMCM/
PRINCIPIA. Thus, we conclude that those different names refer to
the same corporation. For convenience, we shall hereinafter refer
to that corporation as IAMCM.
Petitioners concede that IAMCM never filed Form 2553 with
respondent. The record does not disclose that IAMCM otherwise
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