57) The IRS did not adopt the common request to allow taxpayers to file method change requests any time prior to having an issue under consideration since this provision would have resulted in a large number of disputes regarding when an issue came under consideration.
92-20, the new 90-day window allows taxpayers that have been under continuous examination for 12 months as of the beginning of the year of change to request a change in method of accounting for an issue not under consideration or in suspense during the first 90 days of any taxable year.
under continuous examination additional opportunities to change their methods of accounting voluntarily without significantly increasing the potential for disputes regarding when an issue has come under consideration.
The 120-day window period allows taxpayers to request a method change for issues not under consideration or placed in suspense at the time the request is filed during the 120-day period following the date an examination ends, regardless of whether a subsequent examination has commenced.
Since this interregnum will provide examination agents additional opportunities to raise issues under consideration, the new provision effectively eliminates taxpayers' ability to utilize the 120-day window.
For both of these windows, the taxpayer must attach a separate signed statement certifying that, to the best of the taxpayer's knowledge, the requested method change is not an issue under consideration or an issue placed in suspense by the Examination function.
In addition, taxpayers must provide a separate signed statement that the requested change is not an issue under consideration by Appeals or a federal court.
Taxpayers may not file method changes for issues under consideration or placed in suspense.
This includes production and marketing of goods and services and the financing of the business and other types of organizations; economic, legal, and ethical environments pertaining to profit and nonprofit organizations; concepts and applications of accounting, quantitative methods, and management information systems, including computers; organization theory, behavior, and interpersonal communication; and a study of administrative processes under considerations
of uncertainty, including integrating analysis and policy determination at the management level.