Circumstances for accepting a late or amended election
56. Circumstances where a request may be accepted include:
(a) There have been tax consequences not intended by the taxpayer, and there is evidence that the taxpayer took reasonable steps to comply with the law. …
(e) The later accounting of the transactions by all parties is as if the election was made …
57. A request will not be accepted in the following cases:
(a) It is reasonable to conclude that the taxpayer made the request for retroactive tax planning purposes. …
(c) It is reasonable to conclude that the taxpayer had to make the request because he or she was negligent or careless to comply with the law