Although the language in the Regulation is fairly clear, exceptions can be made (and have been made).
A PLR (link below) allowed the taxpayers to make the election in a later tax year because they "relied on a qualified tax professional and the tax professional failed to make, or to advise the taxpayer to make, the election".
https://www.irs.gov/pub/irs-wd/201607005.pdf
Note that an exception can be made where the "taxpayer failed to make the election because, after exercising reasonable diligence (taking into account the taxpayer's experience and the complexity of the return or issue), the taxpayer was unaware of the necessity for the election".
