Form 14726 – Waive the Final Partnership Adjustment under BBA

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A BBA partnership audit closes in two very different ways depending on what the Partnership Representative does in the final stretch. Wait for the Notice of Final Partnership Adjustment to arrive by certified mail and the 90-day Tax Court petition window opens; the case can stretch on. Sign and submit Form 14726 first, and the agreed imputed underpayment moves straight to assessment with no FPA mailing and no petition clock.

The catch is that only the Partnership Representative can sign this waiver, not the individual partners, and it has to reach the IRS through the BBA Online Forms Submission Service before the FPA goes out. Get the timing or the signature wrong and the agreed closure you were counting on does not happen the way you planned.

Key Takeaways

• Form 14726 is the IRS waiver of the Notice of Final Partnership Adjustment under the BBA audit rules, and it is signed by the Partnership Representative.
• Using the waiver allows the IRS to skip certified mailing of the FPA and proceed to assessment, which avoids starting the FPA petition clock.
• Timing matters. The waiver must be executed and submitted before the IRS mails the FPA, and the IRS will countersign on its end to close the case as an agreed closure.
• Audited BBA partnerships must submit Form 14726 electronically through the IRS BBA Online Forms Submission Service, with a manual signature scanned into the uploaded PDF. Keep proof of submission.
• Only the Partnership Representative, or a properly authorized POA for the PR where allowed, may sign. Partners cannot sign. Maintain evidence of PR designation.

What is IRS Form 14726

Form 14726, Waiver of the Notice of Final Partnership Adjustment, is a short, one‑page form the Partnership Representative uses to waive the IRS’s certified mailing of the FPA under the BBA regime. Once accepted, the IRS can assess and collect the imputed underpayment without issuing an FPA, which means the 90‑day judicial review window that follows an FPA never opens. That is the point, to speed up closure when the substance is settled.

The BBA framework centralized partnership exams beginning with tax years that started in 2018. It replaced TEFRA and the electing large partnership rules, and it requires every partnership that does not validly elect out to designate a Partnership Representative with sole authority to act. If you operate under BBA, Form 14726 is part of your closure toolkit.

When to use the waiver

Use Form 14726 after the exam issues have been resolved and you are not seeking partnership‑level judicial review. In practice, the PR signs Form 14726 so the Service can assess the agreed imputed underpayment and move straight to collection or settlement performance, rather than waiting for an FPA to be mailed. If you intend to petition or need the FPA to trigger a push‑out election window, do not file the waiver.

Rule of thumb, if you want speed and you do not need the 90‑day petition period, consider the waiver. If you anticipate a petition, or you plan to push out based on FPA timing, do not waive.

Two timing guardrails apply. First, the IRS cannot mail an FPA earlier than 270 days after the NOPPA, unless the partnership agrees to waive that 270‑day period. Second, your Form 14726 must arrive and be accepted before the FPA is mailed. Once an FPA is mailed, the 90‑day petition clock starts, and the waiver option is gone.

How Form 14726 fits in the BBA process

Purpose and legal effect

By executing Form 14726, the PR agrees that the IRS may skip certified mailing of the FPA and proceed to assess and collect the agreed imputed underpayment at the partnership level. This closes off the FPA‑driven petition path, since there is no FPA to petition, and it shifts your focus to payment, push‑out paths that were already elected, or other resolved terms in the settlement. The PR’s signature binds the entity.

The waiver does not change the substance of the adjustments. It is procedural. If you negotiated modifications to the imputed underpayment during the NOPPA period, those still control. The IRS will summarize the agreed figures on Form 15027 and will countersign both documents for an agreed closure.

Timing and eligibility

• You are in BBA procedures for the reviewed year.
• A NOPPA was issued and the modification window is closed or waived, or your numbers are otherwise finalized.
• The PR signs Form 14726 and, where applicable, Form 15027, before the FPA is mailed. The IRS reviews, then countersigns to close.

Do not rely on old habits like waiting for certified mail. Under the BBA, audited partnerships submit Form 14726 electronically, and the signature rules are specific. See the IRS BBA Online Forms Submission page for the signature table and file‑format requirements.

Interaction with Appeals

Appeals retains jurisdiction under BBA. The waiver simply removes FPA mailing from the path. If you and Appeals have settled, the waiver lets closure happen without starting an FPA petition window. If you still want Appeals or court review, do not waive.

• Compliance note, this article is general information, not tax, legal, or accounting advice. Confirm current procedure on irs.gov and coordinate with counsel on timing and forum choices, especially if partner‑level outcomes or push‑out strategy are in play.

Eligibility and filing prerequisites

The BBA rules put one person in the driver’s seat, the Partnership Representative. If you want to use Form 14726, the PR must be properly designated for the reviewed year, still empowered, and ready to bind the entity. Partners cannot file this waiver. Your first job is to confirm PR status, PR authority, and the exact reviewed year that is under exam.

Quick checklist you can run in five minutes, PR designation on file, correct EIN and legal name, reviewed year confirmed, NOPPA and modification history in the file, and no intent to petition or rely on an FPA‑triggered push‑out window.

You also need a clean factual record. Gather the NOPPA, any modification submissions, correspondence that resolves issues, and working IU computations. If Appeals is involved, make sure your settlement memo and numbers match what you are about to waive. Finally, do not forget evidence of timely submission. Keep a PDF of the executed waiver plus certified mail or electronic submission confirmation.

Who can file

Only the Partnership Representative may sign Form 14726. If a representative signs for the PR, you need written authorization that explicitly covers execution of an FPA waiver. A partner’s title does not help here. Under the BBA, the PR speaks for the partnership. If you changed PRs midstream, document the succession and make sure the IRS recognizes the current PR before you send the waiver.

• Verify that the PR on the form matches IRS records for the reviewed year.
• If an agent signs for the PR, include the POA and keep it with your file copy.
• Use the exact partnership name and EIN that appear on the reviewed year Form 1065.

Required documentation

You do not file a mountain of attachments with Form 14726, but you should build a tight internal packet to defend your timing and authority later. Include the reviewed year Form 1065, any AAR filings that affected the statute, the NOPPA, modification materials, and IU computations that match the final agreed figures. If any settlement terms reference penalty relief or specific rate selections, include those schedules next to the waiver in your records.

Pro tip, print or save a single PDF binder, waiver first, then the reviewed year 1065 cover, NOPPA, mods, IU worksheet, and submission proof. When someone asks two years later why you waived, you will have the answer in one click.

The Partnership Representative’s role

The PR’s signature on Form 14726 binds the partnership to skip the FPA. That choice closes doors and opens others. It removes the 90‑day Tax Court petition window that follows an FPA. It accelerates assessment and payment. It may limit the timing of any partner‑level push‑out that depends on an FPA date. That is why your PR should pause and map consequences before signing.

As PR, you should also align people and process. Tell your controller or outside CPA when assessment is expected, who will handle payment, and what the communication plan is for partners if push‑out is off the table. If you use a practice management system, drop the waiver date, assessment estimate, and follow‑up tasks on a shared checklist so nothing waits on a single person’s memory.

If your firm struggles with documentation discipline during peak season, write down the PR’s authority evidence and delivery proof the same day you sign. Future you will thank present you.

Timing, statutes of limitations, and critical deadlines

The waiver is simple, the calendar is not. You have three clocks to watch, the three‑year assessment statute, the 270‑day modification window after NOPPA, and the FPA petition window that never starts if you waive properly. Put the dates in writing before you touch the form.

Here is a quick map you can adapt to your file.

Trigger	Clock	What to do
Return filed or due, later of the two	About 3 years	Confirm the base statute. Note any Form 872‑M that extends it.
AAR filed for the reviewed year	About 3 years from AAR filing	Recalculate the statute and update your closure plan.
NOPPA mailed	270 days, extendable	Submit or finalize IU modifications, resolve penalties, and verify numbers.
Pre‑FPA waiver filed	Immediate on acceptance	IRS proceeds without mailing the FPA, so plan for assessment and payment.

If Appeals is evaluating issues, remember that Appeals keeps jurisdiction under BBA. The waiver simply avoids the FPA mailing, which means you get to closure without starting a petition clock you do not intend to use.

How to complete Form 14726

Start at the top and go slow. Enter the legal name, EIN, and tax year of the reviewed year exactly as they appear on the return. Populate the Partnership Representative section with current contact information. Mark the waiver election clearly, attach any referenced schedules if your case uses companion forms, and make sure the signature block is complete. Date matters.

• Cross‑check totals in your IU computation against the numbers reflected in the settlement record or closing documents.
• If your team prepared separate schedules that explain rate selection or partner groupings, attach those to your internal packet so reviewers can retrace the math later.
• Keep a copy of everything you send, exactly as sent, including the signed pages.

Delivery, signatures, and submission methods

Follow the submission instructions in your IRS correspondence. Many BBA cases use electronic submission now, which means you will sign, scan to PDF, and upload. If your procedure requires mail, use certified mail, keep the receipt, and request return service so you can evidence the date the IRS received your waiver. Do not rely on memory or a calendar note. Paper fades and so do inboxes.

Golden rule, if you cannot prove when the IRS received your waiver, pretend it did not happen and fix that gap. Timeliness is what gives the waiver teeth.

Small firms sometimes ask if multiple partners should sign. The answer is no. The PR signs. If your operating agreement expects certain consents, collect those internally, but do not clutter the IRS form with extra signatures that could confuse processing.

Accountably note, many firms stumble on delivery proof and standardized workpapers. Our teams are trained to label files, store submission proof, and maintain version control so reviews go faster and audits close cleanly. If your process breaks during peak season, structure beats heroics.

Effects of executing the waiver on Appeals and litigation

Filing Form 14726 is a procedural choice with real consequences. When the Partnership Representative signs and the IRS accepts the waiver, the Service can assess the imputed underpayment without mailing an FPA. That removes the 90 day Tax Court petition window that an FPA would trigger. If you still want a chance to petition based on an actual FPA, do not waive. If your case is settled and you want clean, fast closure, the waiver helps you get there.

Appeals does not disappear under BBA. Appeals can still evaluate your numbers, penalty relief, and facts. The difference is timing. With a waiver on file, closure can happen without the FPA, so you are not juggling a petition deadline while you finalize payment details. If you already filed in a court, talk to counsel before you sign. You do not want a procedural conflict between the waiver path and an active docket.

Ask yourself before signing, are we trading an FPA petition window for speed on assessment and payment, and is everyone comfortable with that trade.

After the waiver, your next steps move from exam to payment and file hygiene. Schedule the payment, update your partner communications, and store the signed form, submission proof, and final computations in a single place. If you ever need a refund claim or an amended partner return later, you will be glad the paper trail is crisp.

How the waiver interacts with NOPPA, modifications, and the FPA

The path looks like this. The IRS issues a Notice of Proposed Partnership Adjustment, the NOPPA. You get 270 days to request modifications to the imputed underpayment, for example partner amended returns, rate changes, or grouping. Once the numbers are final, the Service would normally mail the FPA by certified mail, which starts a 90 day petition clock. Form 14726 lets you skip that last step, so the Service can assess without the FPA mailer.

Keep these coordination points front and center.

• If you need the FPA date to time a push out, do not waive.
• If you negotiated a reduced IU during the modification window, the waiver does not change those results.
• If you extended the modification period, check that your final numbers match what you intend to waive.
• If you used a Form 872 M or an AAR affected the statute, recalc the clock and document it in your file.

Here is a simple timeline you can mirror in your workpapers.

Stage	What happens	Your move
NOPPA issued	Proposed adjustments land	Decide on mods, gather partner data, build IU worksheet
Modification window	Up to 270 days, extendable	Submit mods, confirm penalty positions, lock numbers
Pre FPA choice	Waive or wait	If settled and no petition planned, file Form 14726
Assessment	IRS posts IU	Plan cash flow or push out that was already elected, update partners

Common pitfalls and best practices

Mistakes on Form 14726 are often simple, wrong signer, wrong timing, or missing proof. Each is preventable.

• Validate signature authority. Only the Partnership Representative can sign. If an agent signs, keep written authorization that covers execution of an FPA waiver.
• Mirror IRS identifiers exactly. Use the legal name, EIN, and reviewed year from the filed Form 1065. Small mismatches can slow processing.
• Document timely submission. Save the signed PDF and the electronic submission confirmation or certified mail receipt in the same folder as your IU computation.
• Confirm your intent. If anyone still wants an FPA driven push out or a chance to petition, do not use the waiver.
• Align internal approvals. If your operating agreement requires consents, collect them internally. Do not add extra signatures to the IRS form.
• Keep your numbers in sync. Tie the waiver to the IU worksheet that matches the final settled amount and rates.

A simple pre filing checklist

• Partnership Representative status confirmed for the reviewed year
• NOPPA and modification history filed and labeled
• Final IU worksheet reconciled to settlement notes
• No plan to petition and no pending action that depends on an FPA date
• Form 14726 completed, signed, dated, and saved as PDF
• Submission method chosen and proof of delivery planned

If your firm routinely hits review bottlenecks, assign a single owner for the waiver packet, one person with the job to chase signatures, confirm numbers, and upload or mail, then to file the proof. One owner beats many helpers.

Where structure helps

Accountants are busy, and peak season magnifies small gaps. Standardized file names, version control, and checklists reduce rework. If your practice uses tools like Karbon, TaxDome, Canopy, Suralink, or Jetpack, add a Form 14726 task template with fields for PR authority, NOPPA date, mod due date, waiver date, and proof of delivery. That turns a one time scramble into a repeatable pattern.

Accountably supports firms that want execution without chaos. Our teams work inside your systems, use SOP driven workpapers, and keep delivery proof tight so your reviews take minutes, not hours. Use us for capacity when you want control, not more inbox traffic.

Accessing the form and official resources

Start with the source, the IRS. Search for “Form 14726, Waiver of the Notice of Final Partnership Adjustment” on irs.gov so you download the current, fillable PDF. Check the revision date on the form’s first page and confirm the signature instructions match the directions in your IRS correspondence. If your case uses an online submission portal, follow that letter’s steps exactly. If you must mail, use certified mail and keep the receipt with a scan of the signed form.

Keep one clean PDF binder, waiver first, then NOPPA, modification submissions, final IU worksheet, and submission proof. If someone asks why you waived, your answer is ready in minutes.

Many BBA cases now allow or require electronic submission. That typically means signing, scanning the wet signature, and uploading a PDF through the IRS system noted in your letter. If your case still runs by mail, do not rely on standard postage. Certified mail protects your timing and your file.

A quick table, what to save and why

Item to save	Why it matters	Where to keep it
Executed Form 14726	Proves who signed and when	Engagement folder, “Executed Forms”
NOPPA and modification records	Shows how you got to the final IU	“Audit” subfolder
Final IU worksheet	Ties numbers to the waiver	“Workpapers”
Submission proof, e upload or certified mail	Defends timeliness	“Proof of Filing”
PR designation evidence	Confirms authority to bind the entity	“Governance”

Common mistakes and how to avoid them

The waiver itself is a one-page procedural choice with a large ripple effect, and the recurring errors I see all sit at the same three junctions: authority, timing, and what the waiver does versus what it does not.

Conclusion and next step

Form 14726 is a small form with a big effect. By waiving the FPA, you trade the petition clock for speed and certainty. If you are done negotiating and you want the IRS to assess without waiting for certified mail, the waiver is the clean path. Confirm the PR’s authority, lock your numbers, file before any FPA is mailed, and keep proof of delivery. That is how you close a BBA exam without drama.

Reusable Checklists

The checklists below are copy-paste ready for firm SOPs and engagement files. Each one is built for a single moment in the waiver workflow, so the PR is not improvising at the keyboard.

Keep 14726 Season From Stalling

BBA closures rarely stall because the numbers were wrong. They stall because the procedural steps around the imputed underpayment, the Partnership Representative's authority, and the submission proof get spread across three inboxes and two off-cycle weeks. The IRS instructions for Form 14726 leave the path clear; the work is keeping that path moving when other client deadlines crowd it.

The fix is not heroic. It is a tight set of pre-signing checks, a single point of submission, and a documentation habit that survives staff turnover. When that runs as a system, the PR signs once, the partnership closes inside the planned window, and nothing important lives in someone's memory.

• Map the reviewed year, the PR of record, and any succession history onto one cover sheet that travels with the waiver.
• Walk every settled item, including the IU computation, modification schedule, and penalty position, into a single binder before the PR signs.
• Confirm in writing with the IRS exam contact that the FPA has not been mailed on the day Form 14726 leaves your office.
• Route submission through the BBA Online Forms Submission Service from one designated owner so the confirmation page never disappears into a shared mailbox.
• Log the assessment estimate and partner-communication tasks in your practice-management system the same day the waiver is filed.

Accountably runs this kind of structured procedural work alongside production through our tax outsourcing and offshore delivery teams, so PRs and reviewers keep their attention on judgment calls instead of file-management drag.

FAQs

Who can sign Form 14726?

Only the Partnership Representative can sign. If someone else signs, you need a written authorization that clearly gives that person the power to execute an FPA waiver on the PR’s behalf. Partners cannot sign in place of the PR.

When should I use the waiver instead of waiting for the FPA?

Use it when the exam is resolved, you do not plan to petition, and you want assessment to occur without the 90 day clock tied to an FPA. If you need the FPA date to time a push out or to preserve a court filing, do not waive.

Does the waiver change the dollar amount of the adjustments?

No. It is procedural. It speeds up closure. Your negotiated adjustments and any approved modifications still control the dollars.

Can I reverse a waiver if I change my mind?

Treat it as final. Once the IRS accepts the waiver and moves to assess, the FPA path is gone. Make the decision only after you confirm strategy, payment, and partner communications.

How do I submit Form 14726?

Follow the instructions in your IRS letter. Many BBA cases use an IRS upload portal. Others still use mail. Either way, keep proof of delivery, a portal confirmation page or a certified mail receipt.

What if we changed the Partnership Representative during the exam?

Document the succession and confirm the current PR is recognized by the IRS for the reviewed year. The PR of record, not a past PR, should sign.

Does the waiver affect a push out election?

It can affect timing. If your plan depends on the FPA date to trigger a push out window, do not waive. If you already took actions that do not need the FPA date, confirm with counsel before signing.

What records should I keep in case of a later refund claim?

Keep the executed waiver, the final IU computation, penalty determinations, payment proof, and submission proof together. Good records reduce friction if you later file a claim.

We heard about Form 14824. Is that an IRS form?

It is not a recognized IRS tax form number. If a document uses that number, verify its source and purpose. When unsure, check irs.gov or ask your exam team.

Is any partner level approval needed before the PR signs?

Legally, the PR binds the partnership. Your operating agreement may require certain consents. Collect those internally, but do not add extra signatures to Form 14726.