Our late Form 8832 seems outside the easy relief window. How do we know when it turns into a private-letter-ruling case?

We intended corporate treatment from formation, but the election was not actually filed, and now enough time has passed that I am no longer sure the standard relief procedure is available. One adviser keeps speaking as if late-election relief is still routine, while another says the case may already be outside the automatic lane and heading toward a much more expensive request.

What I need is a cleaner dividing line. If the entity no longer qualifies under the late-election procedure, I want the team to stop talking like this is a simple form fix and acknowledge that the case may have turned into a private-letter-ruling decision with real cost and time consequences.