@kiddkevin01 wrote:
My question is how do I get the consent of the Commissioner of IRS?
You most likely need to assert that the termination was inadvertent and, in accordance with Section 1.1362-4(c), you will need to make the request in the form of a ruling request.
See https://www.law.cornell.edu/cfr/text/26/1.1362-4
The following is a passage from a PLR requesting a determination that the termination was inadvertent.
The IRS will generally deny consent unless you can show that the termination was not within the control of the corporation or shareholders having a substantial interest in the corporation and was not a part of a plan on the part of the corporation or of such shareholders to terminate the election.
