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The akatsuki leader will not be someone so obvious as the 3rd or Madara; true it seems logical for someone as strong as Itachi to obey only a stronger ninja, such as another MS user as Madara, or someone like Yondaime, but i'm sure Kishi figured ppl would be guessing this all the time. Also, Madara does seem plausible, because Kyuubi knows of him and considers him more cursed than even itself, which would make sense for the Akatsuki leader who apparently has no fear over using the powers of the bijuu. However, when kakashi hinted about the training naruto would go through, many, MANY ppl already concluded that he would use his MS to allow Naruto the time, no one would've guessed the Kage bushins. this alone suggests that kishi thinks outside the box, and would not use Madara or yondaime. But, we'll just have to wait and see.
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