George Hani's comments, made on a June 14, 2017 panel at the Texas Federal Tax Institute about the re-released partnership audit regulations, were mentioned in Tax Notes Today. Hani posed a hypothetical involving a small partnership with four limited partners and a disregarded entity general partner that is a single member limited liability company. That situation seems straightforward, but the partnership cannot elect out of the BBA because there is an LLC, but it could if it was an S corporation, he said.