I think that is a good question why the election is done.  Another way to ask the same question is why there is a Rev Proc. 2013-30.  I came from Big 4 subsequent technical accounting on derivatives.  But due to COVID I am one of the small business player now.  Small businesses are extremely underserved and I am passionate to start new initiatives to bring service quality to small businesses as well. 

Originally it is a question on how to report on a very common scenario that is commonly not done right.  I am just trying to clean this process up.  I did not expect it become an academic debate and that is why I love tax.  So there is basically no answer without digging in case law.  

I did not mean to make you do research - I just think you are very knowledgeable and maybe you have a case number on mind.  If not, that is totally fine.  I am accumulating all these little things and this would be one of the most precious cases in my notes.  

Thank you and I hope you have a great day.