I would say that we were primarily driven by constrains hered… I.e., we did example forms that seemed to be most applicable to our clients… but found ourselves very limited in what we had time and mostly “space” for in the ebook.

In answer to your question about whether to file both 186 and 187 to be safe, I would defer to your professional judgment here. If you think you have a client that requires both, you should file both.

That said, I would guess there’s very little marginal benefit in filing the third or fourth or fifth 3115… I think the riskiest course for CPAs is to not file any 3115s. That seems crazy.

However, given that presumably millions of tax returns will simply omit any 3115s, I would think your or my risk for only filing two instead of three is pretty low. Or maybe I shouldn’t say it that way… Maybe I should say that excuse #1 below sounds a whole lot better than excuse #2 below:

EXCUSE #1: “Oh, gee, Mr. IRS Agent? You’re right… we probably should have done a code 187 too.”

EXCUSE #2: “Oh, yeah, well, our clients didn’t want to pay for any 3115s so we didn’t do them. And we blew off the 8275Rs too.”

Sorry I don’t have a better response.