In enacting Subchapter S of the Code, commonly referred to as S-Corporation, Congress decided to give a certain group of corporations a break from the burden of double taxation. Given this fact, there must be limitations on the corporations that can select S corporation status! Provide an example of one such limitation, including the text of the Code section that provides the limitation. (We might as well get a look at a verbatim Code section or two during the course of this class!