Treasury regulations offer a form of relief allowing a late election, commonly known as "section 9100 relief." Two types of relief are offered by Regs. Secs. 301.9100-1 through -3-automatic relief and nonautomatic relief.
Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/rXi3HygE58w/TPP_July2014_03.aspx
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