cash basis carrying inventory

IRS Pub 538 pages 14 to 16 talks about cases when a cash basis taxpayer can
carry inventory.     Exclude the easy case which is revenue procedure
2001-10, for taxpayers with under one million in gross receipts.   The only
other exception is revenue procedure 2002-28, which talks about taxpayers
that meet these tests:

* Under 10 million gross receipts (using a specific test)

* Not prohibited by section 448 from using cash basis (so that would be C
Corporations and Partnerships with > 5 million gross receipts)

* Eligible business type (there is a list of NAICS codes that are prohibited
for the principal activity of the business)

The general impression one gets from reading the rules for 2002-28 and other
articles online is that the IRS really really does not like any business
that carries inventory to be on the cash basis.  My question is can someone
give me a sense of audit risk from carrying inventory and being on cash
basis, even if you pass the 2002-28 tests?  You get the feeling that even if
you follow 2002-28 strictly, that just being a cash basis taxpayer with
inventory will elevate audit risk a lot.

One article I read online contained the generalization that IRS will test
value of inventory against gross receipts, and if they see inventory >= 15%
of gross receipts then they will change you to the accrual method for the
years under audit.  Is that a fair statement, and are there other tests and
generalizations that can be made to help a cash basis taxpayer that carries
inventory understand whether IRS will require transition to accrual basis
for other reasons than what is in procedure 2002-28 alone?

nish

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