For 9 months of fiscal tax year, there were 3 stockholders.  Their stock was redeemed and issued to 25 stockholders for the remaining 3 months of the fiscal year.  Significant Section 179 purchases were made in the last three months.  Can the allocation of the section 179 be 100% given to the 25 shareholders and 0% to the 3 shareholders  if a Section 1377(a)(2) election is made?