Mr. Lewis J. Fernandez
Associate Chief Counsel, Income Tax and Accounting
Internal Revenue Service
P.O. Box 76A04
Ben Franklin Station
Washington, DC 20044
Re: Suggestions for Processing Accounting Method Change Requests
Dear Mr. Fernandez:
Enclosed are comments prepared by the American Institute of Certified Public Accountants (AICPA) regarding suggestions for improving the processing of accounting method change (CAM) requests. These comments were developed by the 3115 Task Force of the AICPA’s Tax Accounting Technical Resource Panel and approved by the Tax Executive Committee.
The AICPA offers for your consideration the enclosed suggestions 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.
Thank you for this opportunity to share our suggestions on improving the processing of non-automatic method change requests. If you would like to discuss the proposals contained in this letter, please contact me at jeffrey.hoops@ey.com; Christine Turgeon, Chair, AICPA Tax Accounting Technical Resource Panel, at christine.turgeon@us.pwc.com; or Les Schneider, Chair, AICPA 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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