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Part III - Internal Revenue Service Part III Administrative, Procedural, and Miscellaneous 26 CFR 601 105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability (Also Part I, § 1361; 1 1361-1 ) Rev Proc 98-23 SECTION 1 PURPOSE This revenue procedure provides guidance on (1) the conversion of a qualified subchapter S trust (QSST) to an electing small business trust (ESBT