The term “election” for which 9100 relief is available is defined as “an application for relief in respect of tax; a request to adopt, change, or retain an accounting method or accounting period” (Treas. Reg. § 301.9100-1(b)). This definition is broader than most taxpayers would think. However, the term “election” does not include an application for an extension of time to file a return.
a recharacterization could be as late as a valid extension. if you don't have one and did it after 4/15, it was invalid. so now you would have to amend the amended return.
