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@BobKamman wrote:

Check the Internal Revenue Manual.  This applies to one situation but it indicates that credit elects are not processed after end of year.

2

The credit-elect posted is less than the original return requested. The UNAPPLD-CR-ELECT field on CC TXMOD displays the amount of unapplied credit elect from the return.

The date is prior to the end of the processing year in which the credit-elect originated

The computer continues to auto-offset as more credit becomes available until the full credit elect amount is satisfied. Example:   A credit elect from 2022 to 2023 is systemically applied thru Dec. 31, 2023. The adjustment must be posted by the end of the year.

 

https://www.irs.gov/irm/part21/irm_21-006-003r

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That's only in relation to what prefaces that section: "An overpayment is refunded or applied as credit-elect only after all other outstanding obligations are satisfied (spousal obligations, non-tax debts, etc.)."

There are plenty of cases that support the statute and regulations.