Charles, Inc. was a closely held C corporation engaged in the real estate rental business in 2008. The company had $6 million in passive activy...

Charles, Inc. was a closely held C corporation engaged in the real estate rental business in 2008. The company had $6 million in passive activy losses. In 2009, Charles elected to be taxed as an S corporation, and the company sold a number of rental properties. May these suspended passive activity losses (PAL) be claimed as deductions under section 469(g)(1)(A)?