IRS Form 15307 – IRS Forms, Instructions, Pubs 2026

IRS Form 15307 – IRS Forms, Instructions, Pubs 2026 – Large corporations and partnerships under IRS examination face strict accuracy-related penalties for understatements or errors on their returns. IRS Form 15307, officially titled Post-Filing Disclosure for Specified Large Business Taxpayers, provides a targeted solution for eligible taxpayers in the Large Corporate Compliance (LCC) or Large Partnership Compliance (LPC) programs.

This form allows post-filing disclosures of errors, omissions, or uncertain positions to be treated as a qualified amended return, protecting against penalties under IRC Sections 6662(b)(1) (negligence or disregard of rules/regulations) and 6662(b)(2) (substantial understatement of income tax).

Introduced in November 2022 alongside Revenue Procedure 2022-39, Form 15307 replaced the broader disclosure regime under the obsolete Rev. Proc. 94-69 for a specific subset of frequently audited large businesses. No revisions have been issued as of 2026—the current version remains the November 2022 edition available as a free PDF download from the IRS.

This comprehensive guide covers everything you need to know about IRS Form 15307 instructions, eligibility, filing process, required disclosures, benefits, deadlines, and more. Whether you’re a tax director at a large corporation or advisor to a qualifying partnership, understanding this form is critical for minimizing audit risks and penalties during LCC/LPC examinations.

What Is IRS Form 15307?

Form 15307 is a specialized disclosure statement used exclusively by “specified large business taxpayers” selected for examination under the IRS’s LCC Program (which replaced the Coordinated Industry Case or CIC program) or the LPC Program (or their successors).

By completing and timely submitting the form to the examining IRS personnel, eligible taxpayers can:

• Report additional tax due due to errors or omissions unknown at the time of original filing.
• Adequately disclose positions that have a reasonable basis (even if no adjustment results).
• Have the disclosed items treated as if reported on a qualified amended return.

The form standardizes the disclosure process that was previously handled informally under Rev. Proc. 94-69, ensuring consistency for both taxpayers and IRS examiners.

Download the official form here: IRS Form 15307 PDF

Background and Legal Authority

The IRS issued Revenue Procedure 2022-39 on November 16, 2022 (published in IRB 2022-49) to modernize disclosure procedures for large taxpayers subject to near-constant audits.

Key changes:

• Applies only to taxpayers meeting a strict “four-out-of-five” audit history threshold.
• Extends the response window from 15 days (old rule) to 30 days.
• Explicitly treats a properly completed Form 15307 as a qualified amended return under Treas. Reg. § 1.6664-2(c)(4)(ii).

The procedure applies to examinations beginning after November 16, 2022. Transition relief allows continued use of old procedures for certain pre-2021 years.

This framework balances IRS enforcement goals with taxpayer incentives for voluntary compliance on complex issues like transfer pricing, credits, deductions, and uncertain tax positions.

Who Is Eligible for IRS Form 15307?

Eligibility is narrow and determined by the IRS:

• Corporations: Selected for LCC examination and at least 4 of the 5 preceding taxable years’ returns were (or are) under examination under LCC, CIC, or successor programs.
• Partnerships: Selected for LPC examination and meet the same four-out-of-five audit history test under LPC or successor.

The IRS notifies taxpayers in writing if they qualify. The four-out-of-five count is based on the date of first IRS contact for the current examination and includes short tax years.

Ineligible taxpayers must use standard qualified amended return rules (Treas. Reg. § 1.6664-2(c)(3)), Form 8275/8275-R, or Schedule UTP attached to the original or amended return.

Note: Eligibility can fluctuate year-to-year based on IRS audit decisions, so large businesses should track their examination history carefully.

Step-by-Step: How to File Form 15307?

1. Receive IRS Request — The examining agent issues a written request for Form 15307 (typically early in the audit).
2. Gather Information — Review the original return for errors, omissions, or positions requiring disclosure.
3. Complete the Form — Provide detailed information for each adjustment (see next section). Sign under penalties of perjury.
4. Attach Supporting Documentation — Include relevant workpapers, calculations, and any previously filed Form 8275, 8275-R, or Schedule UTP.
5. Submit Timely — Deliver to the IRS examination team no later than 30 days after the written request (or a later date mutually agreed in writing).
6. IRS Review — Examiners determine adequacy; they must notify you if the disclosure is inadequate.

Favorable adjustments (reducing tax) can also be disclosed and treated as an informal claim for refund if they meet Treas. Reg. § 301.6402-2 requirements.

The form cannot be used for foreign tax redeterminations under § 1.905-4 or certain partnership push-out statements.

What Information Must Be Included on Form 15307?

A “properly completed” form requires clear, separate disclosures for each item. The IRS provides examples of acceptable and unacceptable disclosures directly on the form.

Key fields and requirements include:

• Identification of any Schedule UTP, Form 8275, or Form 8275-R filed with the original return.
• For each adjustment:
  • Adjustment Type (e.g., ordinary income, capital gain/loss, IRC § 1231, dividends received deduction, expense deduction, tax credit, other).
  • Timing (permanent, temporary, temporary 1–3 years, temporary 3–10 years, other).
  • Effect on Other Years.
  • Page and Line on the original tax return.
  • Increase or Decrease to Taxable Income.
  • Increase or Decrease to Tax Credits.
• Detailed description that reasonably apprises the IRS of the item’s identity, amount, and nature of the controversy or potential controversy.
• Computation of the net increase/decrease in taxable income or credits for each item (no netting across items).
• Optional: Additional information establishing reasonable basis for a position.

Disclosures must be stated separately—no netting allowed. Incomplete or vague descriptions will not qualify for protection.

Benefits of Using Form 15307

• Full Penalty Protection — Disclosed items are treated as shown on a qualified amended return, so the IRS will not assert §§ 6662(b)(1) or (b)(2) penalties (provided the position has reasonable basis where required).
• Streamlined Process — Avoids filing a formal amended return while still achieving similar treatment.
• Favorable Adjustments — Can reduce tax liability via informal refund claim.
• Consistency for Frequent Auditees — Designed specifically for taxpayers under repeated IRS scrutiny.

Any agreed additional tax flows through normal deficiency or partnership audit procedures.

Deadlines, Penalties for Non-Compliance, and Inadequate Disclosure

• Deadline: 30 days from IRS written request (extendable by written agreement).
• Inadequate Disclosure: IRS notifies the taxpayer; no penalty protection for that item. Determination is made by the examination team (appealable to IRS Independent Office of Appeals in some cases).
• Late or No Filing: Loss of qualified amended return treatment and potential exposure to full accuracy-related penalties.

Always respond promptly and thoroughly—partial compliance does not provide partial protection.

Key Differences from Rev. Proc. 94-69

Aspect	Old Rev. Proc. 94-69	New Rev. Proc. 2022-39 + Form 15307
Eligibility	Broad (most large corps)	Limited to 4-of-5 audit history
Response Time	15 days	30 days
Form Required	Informal letter or statement	Standardized Form 15307
Scope	Broader	Focused on LCC/LPC “specified” taxpayers
Effective Date	Pre-2022 exams	Exams after Nov. 16, 2022

Transition rules protect certain older years.

Frequently Asked Questions (FAQs)

• Is Form 15307 required?
  No—it is optional but highly recommended for eligible taxpayers seeking penalty protection.
• Can I use it before IRS contact?
  No. It is a post-filing, during-examination tool only. File a standard qualified amended return before IRS contact if needed.
• Does it apply to 2025 or 2026 tax years?
  Yes—the form and Rev. Proc. 2022-39 remain fully in effect with no updates.
• What if my company no longer meets the 4-of-5 test?
  You become ineligible; use standard QAR or disclosure rules instead.

Conclusion: Proactive Compliance with Form 15307

For specified large business taxpayers under IRS scrutiny, IRS Form 15307 offers a powerful, standardized way to disclose issues early in an audit and secure penalty protection. By understanding eligibility, preparing detailed disclosures, and meeting the 30-day deadline, companies can reduce audit uncertainty and avoid costly penalties.

Resources:

• Download Form 15307 PDF
• Full text of Revenue Procedure 2022-39
• IRS Large Business & International Division guidance

Tax rules are complex and fact-specific. This article is for informational purposes only and does not constitute tax or legal advice. Always consult a qualified tax professional or your IRS examination team for guidance tailored to your situation.

Last updated February 2026. All information sourced from official IRS publications and Revenue Procedure 2022-39.