One of the areas where tax enforcement is way too lax and public guidance is lacking is the auditing of partnerships and partners. There are several reasons why that is so. First, the usual budgetary constraints to hire new qualified people. Second, not enough information reporting even though corporate partners with audited financials have been filing schedule UTP for years. Consider paying attention to those filings and perhaps expanding the schedule UTP to cover partnerships. Third, there is a very large knowledge gap between inside the Office of Chief Counsel, Passthroughs and Special Industries, as well as in LB&I and SBSE. That is primarily due to the lack of emphasis on partnerships over the past two or more decades, or maybe three decades. And part of the knowledge gap is that partnerships should have its own separate division at the Office of Chief Counsel at the IRS and not just be part of P&SI which handles excise taxes, credits, estate and gift and other matters as well as partnerships. There are only two partnership branches in P&SI. Partnership experts would also be more inclined to want to join the IRS in this endeavor if there was a separate Associate Chief Counsel for that separate partnership division.