January 31, 2008
Mr. George J. Blaine
Associate Chief Counsel (Income Tax and Accounting)
Internal Revenue Service
Ben Franklin Station, P.O. Box 7604
Washington, DC 20044
Re: Comments on Notice 2007-88 – New Procedures for Filing Accounting Method Changes
Dear Mr. Blaine:
The American Institute of Certified Public Accountants (AICPA) offers the enclosed comments suggesting improvements for processing accounting method change (CAM) requests. These comments were developed by the Form 3115 Task Force of the AICPA’s Tax Accounting Technical Resource Panel and approved by the Tax Executive Committee.
Our suggestions focus on reducing the current backlog of CAM requests, primarily by replacing the present CAM approval process with a two-track system under which the great majority of CAM requests could be handled in a more expeditious fashion.
If you would like to discuss these proposals further, please contact me at jeffrey.hoops@ey.com; or Les Schneider, Chair, AICPA Form 3115 Task Force, at lschneider@ipbta.com; or George White, AICPA Technical Manager, at gwhite@aicpa.org.
Sincerely,
Jeffrey R. Hoops
Chair, Tax Executive Committee
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