George Hani's comments at the administrative practice session of the American Bar Association Section of Taxation 2017 Joint Fall CLE Meeting were covered by Tax Notes Today. "Some people have suggested a unified proceeding so all disputes with respect to the underlying adjustment as well as modification requests or anything else goes in one bucket. … Others have said we could do the underlying adjustment to Appeals first because if we can successfully resolve that, there may not be a need for modification," Hani said. Treasury could consider providing some optionality in the dispute resolution process, he said, adding "if you try to make everyone follow one procedure, it's going to get some, but not others." A more flexible process could include something comparable to the fast-track settlement program for specific types of issues, Hani said.