George Hani's comments at the State Bar of Texas' Federal Tax Workshop were included in coverage by Tax Notes Today. During panel presentations on the new partnership audit rules, Hani and his co-presenters addressed the anticipated appeals process for various IRS determinations unique to this new audit regime. "There was a lot of angst when the rules first came out that that revenue agent would be vested with all of the authority and discretion about whether to accept a taxpayer's recommendations, or to unilaterally disallow modification requests," he said, adding that those fears were quelled when officials said there would be a path to Appeals for disputes regarding modification requests.