James Gadwood commented on Rev. Proc. 2015-13, 2015-5 IRB 419, a seven-year-old document that contains the consolidated procedures for taxpayers to change their accounting method for tax purposes. Gadwood agreed that the procedures should be periodically updated, although less frequently than the consolidated list of automatic method changes (currently in Rev. Proc. 2022-14, 2022-7 IRB 502). "But I don't know that you could identify a fixed cadence that would be appropriate on the front end," he said. "If there is an update to the change procedures, which I think would be helpful, I'd like to see a draft revenue procedure issued in the form of an IRS notice that requests taxpayer comments," Gadwood noted. He also suggested that the IRS clarify the audit protection rules for accounting method changes with a negative section 481(a) adjustment.