Revoking a TEFRA 242(b) election

[TPATC]

I have a client that plans to revoke his TEFRA 242(b) election in 2012. He will have a substantial amount of catch up distributions to take into income, so he plans to split it over the two year period. I am looking for information / references on how to calculate the final catch up amount that must be taken into income. I have tracked the delayed amounts every year, but does the catch up amount effectively freeze at 12/31/2011 if he is revoking in 2012, or does it continue to accrue (adjusted up or down based on earnings and actual distribuitons taken into income) through 2013?

[ETA Consulting LLC]

but does the catch up amount effectively freeze at 12/31/2011 if he is revoking in 2012

Yes, because his 2012 distribution is, technically, not "past" due. He has until December 31st to receive this, so his only delay was through 2011. Not sure exactly what you're asking, but I would certainly begin on this line.

Good Luck!