@ruesterholz A taxpayer requested a private letter ruling trying to make a late 475(f) election using REG SEC 301.9100. It was denied. here's the link
https://www.irs.gov/pub/irs-wd/202037007.pdf
In my opinion, based on what it says, if you requested it, I believe that you too would be denied. If you think that your situation is different find a tax pro and get their opinion.
