George Hani commented on the Internal Revenue Service's (IRS) recent directive on information document requests at the midyear meeting of the American Bar Association's Section of Taxation. Linda Kroening, director of the IRS's Large Business and International (LB&I) Division, said the new directive, which outlines a new process for issuing requests during audits, is meant to start a meaningful conversation at the beginning of an audit and is not designed to hold summons enforcement as a threat. Hani, who moderated the panel on which Ms. Kroening spoke, described the directive as a potential "game changer," and many practitioners argue that the directive may lead to more summonses with the increased issuance of delinquency notices if taxpayers fail to provide information. While the IRS directive aims to reflect practices that benefit both taxpayers and exam teams, Hani said it would require both parties to act differently.