George Hani commented on the evolution of Internal Revenue Service (IRS) enforcement procedures for information document requests (IDR). Hani said he believes the updated program is a significant development because it will require a change in behavior by taxpayers and examining agents. "If we are successful in accomplishing those changes in behavior, then the program can be successful," he said, adding that the enforcement procedures will affect every Large Business and International Division (LB&I) taxpayer under audit.

The first directive "is what I like to think of as a teaser," Hani said. "It's a short, one-page document indicating that agents are undergoing training on the issuance of IDRs and that IDRs have at least three basic requirements: they must be issue focused, the IDR needs to be discussed with the taxpayer beforehand, and the discussion would require a discussion of the due date of the response." The IRS issued the second directive and reiterated many of the same principles, which were designed to impose consistency and discipline in the overall process.