Doug Jones timely submitted his 2017 tax return and elected married filing jointly status with his wife Darlene. Doug and Darlene did not request an extension for their 2017 tax return. Doug and Darlene owed and paid the IRS $124,000 for their 2017 tax year. Two years later, Doug (Now divorced) would like to amend his return and claim married filing separate status. By changing his filing status, Doug wants a refund for an overpayment for the tax year 2017 (he paid more tax in the original joint return than he owed on a separate return).

Explain why Doug can or cannot do this. Please provide tax code sections to support the answer!