"this will push part of her prior year SEP IRA contribution into the bucket of excessive contribution"

Wouldn't it push all of the prior year SEP contribution into the excess bucket? In an S Corp, SEP contributions are based on wages. I'm guessing there are no wages in the prior years bc they were a Sole Proprietor.

And what is the reason for the late S Election? "I don't like the tax result as a Sole Prop" doesn't work.