Taproot Administrative Services, Inc. v. Comr., 679 F.3d 1109 (9th Cir. 2012), aff'g., 133 T.C. 202 (2009)

(petitioner ineligible for S corporation status because its shareholder was a Roth IRA, an ineligible shareholder; petitioner taxable as C corporation for tax year at issue; ownership of custodial IRA and Roth IRA could not be attributed to shareholder for purposes of S corporation eligibility; S corporation status terminated at time custodial IRA acquired corporate stock).