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@TaxesTech wrote:

I think that is a good question why the election is done.  Another way to ask the same question is why there is a Rev Proc. 2013-30.

I'll chime in, mostly because I appreciate your being polite.  We need more of that here.

The late election procedures exist for the umpteen cases where the lawyer thought that the accountant was going to file the 2553 and the accountant thought the lawyer was going to do it.  Meanwhile the client put themselves on payroll and rather than try to unwind a bunch of payroll that has no business being on Schedule C the IRS allows the late election.  They don't want to have to process all of those amended payroll returns either.

If you read the RP though you'll find that it requires that "The Requesting Entity intended to be classified as an S corporation".  IMO if you never started payroll then it's hard to argue that an S election is anything more than an afterthought.

Rick