I have a situation where a client approached our firm and that client's previous CPA had not filed an S Corp election for his Corporation. The client was under the impression that the S corporation election was timely filed.

The CPA did not file any tax returns dating back to 2004! Can any CPA suggest what we can do, the client badly needs an S Corp status as he has substantial losses that need to be offset against his other passthru income from other S Corporations?

My research suggests that IRS generally will approve S Corporation retroactively but for only a couple of years!

Thanks a lot...