Rev. Rul. 64-250

M , an electing small business corporation within the meaning of section 1371(b) of the Internal Revenue Code of 1954, was reincorporated in a state other than that of original incorporation. The shareholders of M accomplished the reincorporation by organizing a new corporation, N , in the other state and merging M in N . The transaction qualified as a reorganization under section 368(a)(1)(F) of the Code. The surviving corporation, N , also met the requirements for qualification as a small business corporation under section 1371(a) of the Code.

Held , under the facts presented, the reorganization, under section 368(a)(1)(F) of the Code, did not cause a termination of the election under section 1372 of the Code.