George Hani will discuss how the the IRS audit dynamic may change once the IRS has at its disposal the information expected to be included on the schedules of Uncertain Tax Positions described in Announcement 2010-9. The IRS's creation of Issue Management Teams and the designation of issues as Tier I, II, or III issues created complex and frustrating dynamics for IRS audits with a significant, and largely adverse, impact on the ability to resolve issues administratively. Will the new disclosure schedule add insult to injury or allow the IRS to bring a greater degree of certainty earlier in the administrative process?