1.  Where does it say anything about 180 days?  Which line in the current Section 1.446-1(e)(3)(i)??

2.  Even if it was the rule, the info discussed herein is based on an implied and understood "IF APPLICABLE" basis.   IF applicable, means the asker would need to make sure to cross the T's and dot the I's for his/her/its/their case. 

3.  Joshua barks based on the questions asked and the facts given.  For example, even if your point (regarding the 180-day rule) was valid, the answer to your question could possibly be:

3.1  The TP files on a fiscal year basis.

3.2  The TP will make the election for the year 2022.

4.  Here is an excerpt from Journal of Accountancy, in the issue dated March 31, 1998 (!!).  Yes, 1998.  See https://www.journalofaccountancy.com/issues/1998/apr/grimes.html

EXECUTIVE SUMMARY
THE IRS ISSUED PROCEDURES, TERMS and conditions for obtaining the IRSs consent to an accounting method change. Many of the previous complex rules have been eliminated.
USUALLY, AN ENTITY FILES FORM 3115 in the year of change. Under the old procedure, the time for filing was the first 180 days of the tax year. The IRC section 481-a adjustment period in general, is four years, beginning with the year of change for both positive and negative adjustments.

The current requirements for timely filing Form 3115 are in the instructions.  NO mention of the 180-day rule.

That said, regardless, in case missing the 180-day rule is Mea Culpa (I know the spelling of this term because I use it a lot), bear in mind that the responding post generally stated: "IF NO 3115 was filed.... then...." 

Again, the Asker has to do his/her/its/their due diligence.  To me, it is the basic understanding of this forum.   This is actually the main point of this posting.

That said, for the 180-day rule, correct me (still thinking it isn't applicable) if I'm wrong. 

Meanwhile, I'm nursing an urge of finding myself a DeLorean, setting the clock to 1997, stepping on it and pumping it to 88 miles per hour, to see if I could go back to experience the 180-day rule.