Printable Form 2026

IRS Form 14726 – Waiver of the Notice of Final Partnership Adjustment (FPA)

IRS Form 14726 – Partnerships audited under the Centralized Partnership Audit Regime (BBA) — effective for tax years beginning on or after January 1, 2018 — often encounter the Notice of Final Partnership Adjustment (FPA). IRS Form 14726 allows the Partnership Representative (PR) to voluntarily waive issuance of this formal notice, enabling faster assessment and collection of any imputed underpayment.

This SEO-optimized guide draws exclusively from official IRS sources (irs.gov forms, instructions, Internal Revenue Manual, and BBA procedures as of February 2026). It explains what Form 14726 is, when and why to use it, how to complete and submit it, key benefits/risks, and related processes. Download the official PDF here: https://www.irs.gov/pub/irs-pdf/f14726.pdf (Rev. October 2020, still current).

What Is the BBA Centralized Partnership Audit Regime?

The BBA (enacted in the Bipartisan Budget Act of 2015) shifted partnership audits from the old TEFRA rules to a centralized system. The IRS now:

  • Examines partnership-related items at the partnership level.
  • Assesses and collects any imputed underpayment (IU) directly from the partnership (default rule), unless modified or pushed out.
  • Requires designation of a Partnership Representative (PR) with sole authority to bind the partnership.

Key phases include:

  • Notice of Administrative Proceeding (NAP)
  • Notice of Proposed Partnership Adjustment (NOPPA)
  • Optional modification requests (Form 8980 series)
  • Final Partnership Adjustment (FPA) — or waiver via Form 14726

BBA Roadmap for Taxpayers (IRS Publication 5388) — Visual overview of the audit timeline, including NOPPA (270-day modification window), FPA issuance, and post-audit options (pay or push-out).

What Is the Notice of Final Partnership Adjustment (FPA)?

The FPA (typically Letter 5933/5933-A + Form 15027 + Form 886-A) is the IRS’s official final determination of adjustments, imputed underpayment, and any penalties. Mailed by certified mail to the PR and partnership, it triggers:

  • 90 days to petition U.S. Tax Court.
  • 45 days to elect push-out under IRC §6226 (partners report adjustments on their returns via Forms 8985/8986).
  • Assessment period begins (generally 1 year after FPA mailing under IRC §6235, unless waived).

Without an FPA (or waiver), the IRS generally cannot assess immediately.

Purpose of IRS Form 14726: Waiver of the FPA

Form 14726 lets the PR waive the right to receive the FPA under IRC §6231 and waive assessment limitations under IRC §6232(b). By signing:

  • The partnership consents to immediate assessment of the agreed imputed underpayment (and penalties).
  • The IRS can countersign and close the case faster — often within the same cycle as modification approval.
  • The waiver is conditional until the IRS official signs it on behalf of the Commissioner.

Important note from the form language: Signing waives the ability to contest adjustments in court (unless new adjustments arise) and prevents the partnership from electing the §6226 push-out alternative to payment of the imputed underpayment.

This form is commonly paired with Form 15027 (Partnership Summary of Approved Modifications and Imputed Underpayments) when modifications are approved and the parties agree.

When Should You File Form 14726?

Use Form 14726 when:

  • The partnership fully agrees with the final adjustments and modifications.
  • No judicial review (Tax Court petition) is planned.
  • Speed is essential — e.g., to avoid delays from certified mail or the 90-day window.
  • You want to proceed directly to payment or collection.

Do NOT use it if:

  • You may want to push out adjustments to partners (§6226 election timing depends on FPA date in many cases).
  • You anticipate needing the 90-day petition period.
  • The case is still in Appeals or modifications are incomplete.

Typical timing: After NOPPA + modification determination (Letter 5975 + Form 15027), but before the IRS mails the FPA. The IRS cannot issue an FPA earlier than 270 days after NOPPA unless waived.

Who Can File Form 14726?

Only the Partnership Representative (PR) designated on the partnership’s return (or properly updated) — or a Designated Individual (DI) if the PR is an entity. The PR has sole binding authority under IRC §6223.

A valid Power of Attorney (Form 2848) may sign on behalf of the PR if authorization explicitly covers FPA waiver actions.

How to Complete IRS Form 14726 (Step-by-Step)?

The one-page form (fillable PDF) is straightforward:

  1. Partnership Information — Legal name, EIN/TIN, tax year ended (mm/dd/yyyy), full address.
  2. Partnership Representative Information — Name, TIN, address, phone.
  3. Designated Individual (if PR is an entity) — First/middle/last name, TIN, address.
  4. Waiver Statement — Read the pre-printed language confirming waiver of FPA notice, assessment limitations, no court contest (with exceptions), and no §6226 push-out election.
  5. Signature — PR or DI signs manually; enter date, phone, printed name, and entity PR name (if applicable).
  6. IRS Countersignature section (left blank for IRS).

Tips:

  • Use exact names/EINs as on the original Form 1065.
  • No special characters (per current e-submission rules).
  • Keep a copy with your audit file.

How to Submit Form 14726 (Current Electronic Rules – 2026)?

Since mid-2025, audited BBA partnerships and pass-through partners must submit Form 14726 electronically via the BBA Online Form Submission Service (OFSS).

Steps:

  1. Apply for a PBBA Transmitter Control Code (TCC) via e-Services (ID.me account required).
  2. Download the official fillable PDF from IRS.gov (do not complete in browser).
  3. Print → Manually sign (by PR/DI) → Scan to PDF (manual signature required; no separate file).
  4. Upload via https://la.www4.irs.gov/ofss/app/ (use your PBBA account).
  5. Receive Receipt ID; track status with Audit Control Number (ACN) and TCC.
  6. Files <100MB, specific naming conventions, no encryption/passwords.

Paper/fax/email is generally not accepted for BBA forms unless IRS specifically instructs otherwise. Rejected submissions must be corrected and resubmitted promptly.

Pro tip: Submit together with Form 15027 when possible for seamless agreed closing.

Benefits and Risks of Filing Form 14726

Benefits:

  • Accelerates case closure and assessment (no waiting for FPA mailing).
  • Reduces administrative burden and potential interest accrual.
  • Ideal for clean, fully agreed modifications — example: partnerships that negotiated successfully can close in the same cycle.

Risks/Considerations:

  • Irreversible once IRS countersigns — no later petition or push-out election.
  • May affect partner-level timing or communications.
  • Confirm PR authority and internal approvals (operating agreement) before signing.
  • Statute of limitations still applies (generally 3 years from return due date, extendable via Form 872-M).
  • Form 15027 — Summary of approved modifications + IU (often submitted with 14726).
  • Form 8980 — Modification request.
  • Form 8988 — Push-out election (not available if 14726 signed).
  • Form 14791/14792 — Preliminary or agreed examination changes (earlier stages).
  • Forms 8985/8986 — Push-out statements to partners.

Frequently Asked Questions (FAQ)

Can I revoke Form 14726 after submission? No — it becomes binding once IRS countersigns.

Does waiving the FPA stop interest? No — interest continues until paid, but faster assessment can minimize further accrual in some cases.

Is Form 14726 required? No — it is optional for agreed cases.

Where can I find the latest version? Always use the official link above (Rev. Oct 2020 remains current).

Final Thoughts

IRS Form 14726 is a powerful efficiency tool for BBA-audited partnerships ready to close quickly without litigation or push-out. When used strategically after full agreement on modifications, it saves time and resources for both the partnership and IRS.

Always consult your tax advisor or partnership counsel before signing — PR authority and strategic implications are critical. For the most current procedures, refer directly to:

  • IRS BBA Centralized Partnership Audit Regime page
  • Electronic Submission of BBA Forms page
  • Relevant IRM sections (4.31.10, 4.31.13, 8.19.14)

Download the official IRS Form 14726 PDF here: https://www.irs.gov/pub/irs-pdf/f14726.pdf

This guide reflects trusted IRS sources as of February 2026. Tax rules can change — verify with the IRS or a qualified professional for your specific situation.