L. S. Ayres Indianapolis on October 13, 1961. This subsidiary was one of the first discount store divisions launched by a traditional department store. The Indianapolis Ayr-Way store opened prior to the first Kmart, which opened in Garden City, Michigan, in March 1962, and the first Target store, which opened in May 1962. Ayres also opened Ayr-Way stores in other cities. Ayres encountered several challenges in establishing and operating the new discount store concept. First, Ayres needed to define a clear brand identity for the new subsidiary and its relationship to the L. S. Ayres store brand. Second, errors in selection of store
S corporation of gross receipts and (ii) it has accumulated earnings and profits. § 1362(d)(3). An S corporation will only have accumulated earnings and profits if it was a C corporation at some time, or acquired or merged with a C corporation. The S election affects the treatment of the corporation for Federal income tax purposes. The election does not change the requirements for that corporation for other Federal taxes such as FICA and Federal unemployment taxes. While an S corporation is not taxed on its profits, the owners of an S corporation are taxed on their proportional shares of the S