ADD
(a) Adjustments attributable to conversion from S. Corporations to C Corporations - section 481 is amended by adding at the end the following new subsection:
(a) Adjustments attributable to conversion from S corporation to C corporation
(1) In General in the case of an elligable terminated S. Corporation any increase in tax under this chapter by reason of an adjustment required by subsection (a)(2) and which is attributable to such corporations revocation described in paragraph (2)(A)(ii), shall be taken into account notably during the 6-taxable year period beginning with the (unknown)