Calvin calls you and tells you that his two person S Corporation was audited by the IRS last year and they terminated his S Corporation election effective three years ago because the other owner was a nonresident alien. Calvin got his brother to buy all of Helgas stock on December 31, 2022, and now both of the owners are United States citizens and both are equal 50% owners. Can they now elect back into S Corporation status for 2023? What are the rules?