
The BBA Partnership Audit Playbook: Partnership Representatives, Push-Out Elections, and the Imputed Underpayment Trap You Did Not See Coming
Under the Bipartisan Budget Act centralized audit regime, the IRS assesses partnership tax adjustments at the entity level at the highest individual rate. This guide explains when to elect out under Section 6221(b), how the partnership representative can modify or push out the imputed underpayment under Section 6226, and how to file an administrative adjustment request on Form 8082.










