George Hani was quoted regarding the Internal Revenue Service's (IRS's) willingness to expand the list of partnerships eligible to elect out of the forthcoming tax audit regime, which he discussed at the June 14, 2017 Texas Federal Tax Institute in San Antonio. "I think it's safe to assume that it will be very difficult to get an expanded list—at least for now," Hani said, but that doesn't mean the government won't expand the list down the road when it has more experience with the new regime. If practitioners hope to persuade the government to make adds, they need to convince Treasury and the IRS that any changes would "make their life easier, not just make your life easier," he said. One area where Treasury and the IRS may stand to benefit from exercising their authority and adding to the eligible partner list is with consolidated groups. "I've had experiences where there are partnerships within consolidated returns, and so within one consolidated group," he said. Under the outgoing audit regime, consolidated groups that have partnerships within their structures can have multiple TEFRA audits running parallel with the audit of the consolidated return. "Quite frankly, that was more complicated than just auditing everybody together," Hani said. Moving forward, he added, it would make the government's job easier if partnerships within consolidated groups could opt out of the BBA audit regime so that all partnership issues were audited as part of the consolidated return audit.