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CCH (cch.taxgroup.com) reports:

A parent corporation continued to exist for purposes of federal tax law after its conversion into a limited liability company (LLC); thus, it had standing to file for tax refunds for tax years before its conversion. The corporation could not rely on Reg. §301.7701-3(g)(1)(iii) to argue that, after its conversion, it became a disregarded entity and, therefore, nonexistent for federal tax purposes.
The corporation was not an "eligible entity" or an "eligible entity classified as an association" for application of the regulation. Moreover, the corporation did not make an election as required under Reg. §301.7701-3(c)(1)(i), either before or after its conversion, that it was an eligible entity and should be disregarded. Therefore, the court had jurisdiction over its refund requests.
Unpublished opinion, rev'g and rem'g, per curiam, a FedCl decision, 2007-1 USTC ¶50,374.
Browning-Ferris Industries, Inc., CA-FC, 2008-1 USTC ¶50,297
Other References:
Code Sec. 7422
CCH Reference - 2008FED ¶41,688.364
CCH Reference - 2008FED ¶41,688.562
Tax Research Consultant
CCH Reference - TRC LITIG: 9,052
CCH Reference - TRC LITIG: 9,060