Someone, in 1998, converted an IRA which had about $20,000 in it, to a
Roth IRA. However, they did not file a tax return for 1998 and they
are in the process of preparing returns for 1998-2001. If they had
filed a timely return in 1998, they could have spread out the income
over a four-year period.

My question is whether, when they now file their return for 1998, can
they still spread the $20,000 over a four-year-period? Or, was there a
requirement that they had to file the four-year election with their
1998 return AND DID THAT RETURN HAD TO BE TIMELY.

I am an attorney, but I do not do tax work. Please cite me to which
regulations provides for and which cases rule on the issue.