wrote in :

When I used to be a CFI-I (gad, I glad those days are behind me ;-) we
never, ever requested a VFR restriction during training. If, sometimes,
the controller would issue one we would request an IFR clearance. And,
in my early days at the airline, when we had to take 6-month checks in
the aircraft, company policy was IFR, period. But, some check pilots
would violate that policy to expedite things. Scud running in a 727 at
5:00 AM over the hills southeast of KONT isn't a whole lot of fun.

We normally file IFR for our 6-month checkrides. We used to for the annual
recurrent, but that's done in the sim now. Some checkpilots don't want to
file, and I don't argue with them either way. That's not a smart way to
start a ride........