AC-61-98B goes a bit further
"However, a pilot may not take a flight review in an aircraft for which he or she does not hold a rating or operating privilege."
While you can argue the SEL rating covers all SEL airplanes, your candidate can not operate a tailwheel airplane. The simple way to think about is what happens when he balls up a 172 during a crosswind landing next year. The Feds will ask how you could judge his landings in an aircraft he can't land.