paragraph (1) to pay the net first-year tax liability under this subsection in installments— (i) no installment of such liability shall— (I) in the case of a request for credit or refund, be taken into account as a liability for purposes of determining whether an overpayment exists for purposes of section 6402 before the date on which such installment is due, or (II) be treated as a tax imposed by section 1 for purposes of section 6654, and (ii) the first sentence of section 6403 shall not apply with respect to any such installment. (6) Elections (A) In general Any election under paragraph (1), (3)(A), or (4)(A) shall be made not later than the due date for the return of tax for the first taxable year described in paragraph (1) and shall be made in such manner as the Secretary shall provide. (B) Extensions The Secretary shall by regulation prescribe such circumstances and procedures under which extensions of time will be granted to make any election under paragraph (1), (3)(A), or (4)(A). In determining whether to grant relief under this subparagraph, the Secretary shall take into account all relevant circumstances and the time for making the election shall be treated as not expressly provided by statute. (b) Treatment of taxpayers leaving and reentering applicable status If a taxpayer's status as an applicable taxpayer is terminated under section 495(a)(4) and the taxpayer is again treated as an applicable taxpayer for a subsequent taxable year by reason of meeting the requirements of section 495(a)(1)(A), the following rules shall apply: (1) Subsequent year not treated as first year of applicable taxpayer status Subsection (a) shall not apply to any taxable year in which the taxpayer is again treated as an applicable taxpayer and such subsequent taxable year shall not be treated as the first taxable year for which the taxpayer is an applicable taxpayer for any other purpose of this part. (2) Nontradable assets If there is an applicable transfer by a taxpayer of a nontradable covered asset after the taxpayer is