George Hani was quoted regarding the Industry Issue Focus (IIF) program, saying that the IRS tries to measure "materiality" in determining which issues to place on the tiered issue list, and in some directives has set thresholds. He said Tier I and Tier II issues have tended to bring in all the connotations of tax shelters, which Hani described as "bad taxpayer, more dug-in response, and more frequent use of the word 'summons' from field agents."

Hani's comments were made at an April 9 DC Bar Taxation Section Tax Audits and Litigation Committee program. He was joined on the program panel with Frank Ng, IRS Large and Mid-Size Business (LMSB) Division Commissioner, and Miller & Chevalier member Marc Gerson.