Bud is a corporate calendar year taxpayer that has been under exam for 18 months. It is currently August of 2024 and she would like to file an automatic accounting method change for the 2023 calendar year. Bud properly extended her 2023 tax return to September 15th, 2024. The request involves a change from an impermissible method to a permissible method. The method is not an "issue under consideration". The exam is scheduled to end in May of 2026. Under which opportunity is Bud eligible to file an accounting method change with audit protection for the 2024 taxable year