Coved distribution tax payments

I know that coved distributions require either inclusion in income in the year it was taken, 3 year option or re-contribute part or all of the original distribution. I have a new client who took an 80K distribution in 2020 and did not include it in their 2020 return. The distribution that was taken was immediately used up and they lacked the funds needed to make the initial inclusion of one third of the total amount. We are planning to file an amended return and electing the three year option assuming we can go back and make that election. The question I have is there any possibility of starting the three year payment option in the following year when they started to rebound financially?



If Form 8915 E was never filed, I believe the default income reporting is 1/3 for 2020-2022. There is no option to reporting the first 1/3 of the CRD in a year later than 2020, making the due date for tax due 5/17/2021.



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