GREAT QUESTION, TaxGuyBill. The short answer is "I won't be requesting a change in accounting method, I'm at risk that the IRS will dictate it." I am at risk that they will order a tax recalculation back beyond 3 years because they disagree with a revenue allocation done in those years and that THEY will use "change in accounting method" as their justification for ignoring the 3 year statute of limitations. Without going into unnecessary details, they did just that to me and my partners on a completely separate and different transaction in 2005, reaching back to the original transaction 7 years prior to recalculate taxes and interest.
