Client is sole S/H in an S-corp. He plans to move out of state, shutting down the current s-corp, and opening an identical business in his new state as an LLC electing s-corp treatment. He appears in every way to meet the requirements for a tax-free F reorganization under section 368(a)(1)(F) of the Code. The only thing that concerns me is that all publications, court cases, etc., specifically reference corporate to corporate changes, and I'm unsure if the fact that this is an s-corp to LLC electing s-corp treatment would be a disqualifying factor. Thoughts? Thank you for any insight you may provide.