(a) Availability of election. A section 336(e) election is available if seller or S corporation shareholder(s) dispose of stock of another corporation (target) in a qualified stock disposition (as defined in § 1.336–1(b)(6)). A section 336(e) election is irrevocable. A section 336(e) election is not available for trans-actions described in section 336(e) that do not constitute qualified stock dispositions.
CFR 26-1.336-2-2013 history
2013CFR 26-1.336-2-2013 Internal Revenue. Part1:Income taxes(continued). Section1.336-2:Availability, mechanics, and consequences of section 336(e) election.