Since the addition of Subchapter S to the 1954 Internal Revenue Code in 1958, many articles have been written on the interpretation and application of the provisions of this Chapter to various factual situations. At the time of their publication, the final Regulations and pertinent Internal Revenue Service Rulings on the subject had not been promulgated. The subsequent promulgation and issuance of these Regulations and Rulings, therefore, had the effect of abrogating many of the proposals which had been advocated in these articles. These Regulations and Rulings did not answer all of the questions, and until such time as there is case law on the subject, there will remain many unanswered questions. This article could not, and it does not, deal with the complex Subchapter S provisions of the Code in light of their impact upon each particular fact situation, but it is the hope of this author that the considerations brought forth herein will be of value in assisting the attorney to better appraise his client's situation in relation to Subchapter S.
Edward M. Greenwald, Tax Subchapter S Becomes Clearer, 9 Clev.-Marshall L. Rev. 566 (1960)