The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-border activities, and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships that elect out of the centralized audit regime, the IRS will have to audit, assess, and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.