In a prepared statement, the AICPA wrote that relief under section 9100 "is extremely valuable for taxpayers who miss the opportunity to make certain tax elections" and that "Congress should consider making section 9100 relief available for all tax elections, whether prescribed by regulation or statute."

The Institute listed 26 elections set by statute for which the IRS cannot give taxpayers relief on missed deadlines. The AICPA said its list does not cover all elections under discussion

In order for IRS to grant relief under section 9100, Congress must give the IRS authority to do so and taxpayers must show that they have acted reasonably and in good faith and that relief will not harms the government's interests.