The following corporations would like to make an S election. Indicate whether an S election is permitted, and if not, why not?

a. Thompson Corporation is a corporation involved in the production of ink pens. It has 120 shareholders, 60 of which are married couples (i.e. 30 couples).

b. Allen Corporation is a domestic corporation that does investments in foreign countries. It has 75 shareholders (none are married couples) and has two sub-classes of common stock: Common A and Common B.

c. ETF Corporation is a corporation with a net worth of $5,000,000. It has two shareholders: John Ellis, who is a citizen and resident of the United States and Tomas Fernandez, a citizen and resident of Costa Rica.

d. Mellon Corporation is a corporation that is in the mineral development business. It is owned equally by Marion Tyler and Tyler Investment Corporation.

e. Tremont Corporation is a corporation that is involved in banking. It has banking outlets in four Midwestern states.