Form 15057 – Rescind a Final Partnership Adjustment

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A BBA partnership receives a Final Partnership Adjustment, then the IRS and the partnership agree the adjustment never should have gone out. Form 15057 is how both sides unwind it. Once it is signed, the FPA is treated as if it had never been issued.

Two conditions have to hold before you reach for it. The statute under IRC §6235 must still be open, and no court petition can have been filed on that FPA. Signing also surrenders the partnership's §6234 right to challenge that FPA in court, and those rights revive only if the IRS issues a new one.

Key Takeaways

• Form 15057 rescinds an issued FPA when the IRS and the partnership agree to unwind it (signing surrenders the partnership's §6234 right to challenge that FPA in court; those rights only revive if the IRS issues a new FPA). It is two pages, revised February 2019, and remains current as of December 18, 2025.
• You can only use it while the statute is still open under IRC §6235 and only if no court petition has been filed on that FPA. The form text requires both conditions.
• Submission is simple but precise. The partnership representative or designated individual signs, then you submit it to the IRS contact listed on the FPA (not to a generic IRS service center, Appeals office, or fax number). The agreement is effective on the IRS countersignature date.
• Timing matters more in 2025. Recent Tax Court guidance reinforced statutory FPA timing limits under §6235. Track dates carefully when planning a rescission.
• Document downstream impacts. A rescission returns everyone to pre‑FPA status. Reconfirm partner impacts, filings, and any push‑out or modification choices.

What is IRS Form 15057?

IRS Form 15057, Agreement to Rescind Notice of Final Partnership Adjustment, is the official document the partnership and the IRS sign to cancel a previously issued FPA. If accepted and countersigned, it is treated as if the FPA was never issued, which means the partnership cannot pursue a court petition on that rescinded notice and the IRS may, if needed, issue a new FPA later in an amount that is higher than, the same as, or lower than the original adjustment (rescission does not cap the IRS at the prior number). The current form is a two‑page fillable PDF, revision February 2019 (Form 15057 is a procedural agreement form, not an annual return, so it is not revised yearly; the February 2019 revision still applies to 2025 partnership audits).

Why and when you use it

Use Form 15057 after an FPA issues, when both the IRS and the partnership agree the FPA should be withdrawn. Common reasons include material factual corrections, procedural defects, or a negotiated settlement path that makes the original FPA unnecessary. Rescission formally resets the case to the status that existed right before the FPA went out, which is often the cleanest way to correct the record before any downstream computations or payment mechanics kick in. For field teams, the IRS IRM also outlines how incoming rescission requests are validated and countersigned on a tight timetable tied to the FPA default date.

2025 timing context you should know

In a reviewed opinion on July 2, 2025, the Tax Court held that Treasury’s regulation could not extend the statutory time for issuing an FPA beyond what §6235 allows. The court emphasized that the 270‑day period tied to a complete modification request begins when the partnership submits everything required, not when the overall modification window ends. That ruling sharpened timing discipline for both taxpayers and the IRS. If your rescission decision rides alongside modification or petition deadlines, confirm the exact dates before you proceed.

FPA, not FPAA

If your firm worked under TEFRA, you might remember the FPAA. Under the BBA regime, the final notice is called an FPA, and the form to rescind it is Form 15057. Align your internal checklist and templates with the BBA terms so your submission matches IRS usage.

Who should file and who signs

Form 15057 is filed at the partnership level. The signer is the Partnership Representative, or the designated individual if the PR is an entity, acting on behalf of the partnership – no general partner, tax matters partner, or attorney may sign in their place under the BBA centralized partnership audit regime. If a practitioner is involved, make sure Form 2848 authorizes rescission actions and that your engagement letter reflects that scope. The IRS form instructions make clear that the PR or designated individual’s signature is required, and the agreement becomes effective only when the IRS countersigns.

Quick eligibility check

• The FPA has already been issued.
• The §6235 period for adjustments is still open.
• No petition has been filed on the FPA you seek to rescind.
• The IRS contact on the case is aligned that rescission is the right path.

When to use it vs when not to use it

Situation	Use Form 15057?	Why
Material factual error discovered after FPA issuance and both sides agree to reverse	Yes	Rescission returns both parties to pre‑FPA status so the record can be corrected.
Procedural defect in the FPA package acknowledged by IRS	Yes	Formally vacates the notice without litigation.
You want to litigate the FPA in court	No	Filing a petition forecloses rescission on that notice.
You need more time before an FPA issues	No	That is a modification or timing strategy, not a rescission. See §6235 timing rules.
You want to push out adjustments to reviewed‑year partners under §6226	No	That is a push‑out election, not a rescission tool.

How to access the current fillable PDF

You can download the current two‑page PDF directly from IRS static files. Verify the filename f15057.pdf and the revision date February 2019. Save a blank copy in your firm’s secured templates folder, then create a client‑specific working copy for the engagement.

Download checklist

Step	Action
Locate	Go to the IRS PDF directory listing and confirm “f15057.pdf.”
Verify	Confirm revision “(2‑2019)” appears in the PDF header.
Download	Save locally, then lock the blank template in your document control system.
Retain	Keep both the executed PDF and proof of submission in your permanent file.

Step‑by‑step filing walkthrough

• Gather the FPA details you will reference on Form 15057. Pull the FPA date, audit control numbers, the partnership’s legal name, address, and EIN exactly as shown on the FPA.
• Confirm authority. Identify the Partnership Representative and, if the PR is an entity, the designated individual for the tax year at issue. Validate your power of attorney if a practitioner will coordinate the package.
• Complete the form. Enter the required identification fields, then review the agreement text, which includes the statute‑still‑open statement and the no‑petition affirmation.
• Sign and route. The PR or designated individual signs. Submit the completed form to the IRS office and attention line shown on the FPA. The agreement becomes effective when the IRS countersigns, not on the date the partnership representative or designated individual signs.
• Update your file. Save the executed form and the IRS countersigned copy, then update your internal timeline. If the IRS intends to issue a new FPA, expect that process to restart under the IRM.

What happens inside the IRS

The IRM directs personnel to review incoming Form 15057 requests, prepare the appropriate letter package, and get a countersignature before the FPA default date. That internal clock is one reason your package needs to be clean, complete, and timely.

Practical example

Say your team reconciles a complex 704(c) allocation and finds a data import error that drives the imputed underpayment in the FPA. You and the IRS agree the FPA should not stand. You submit a Form 15057 package, the IRS countersigns, and the case returns to pre‑FPA status. You fix the underlying facts and expect a new FPA or an agreed resolution based on the corrected record. That is the clean pathway Form 15057 is built to support.

Timing rules that shape your rescission strategy

Your rescission must land while the §6235 period is open. The IRM explains FPA timelines and the default date, and, as of August 29, 2025, includes procedures related to Form 15057 handling. In July 2025, the Tax Court further reinforced that statutory clocks govern FPA issuance, especially when a partnership has submitted a complete modification request. Those two anchors, the IRM procedures and the court’s timing analysis, should guide your calendar.

Key timing reminders:

• Track the date the FPA was mailed.
• Track any modification submission dates that could affect the §6235 clock.
• Remember the 90‑day petition window starts on the FPA mailing date. If you file a petition, you cannot use Form 15057 on that notice.

Documentation that speeds review

• A clean copy of the FPA and any enclosures.
• A short cover memo that states why rescission is warranted, with cites to facts or procedures.
• Supporting schedules, corrected workpapers, or correspondence that show the path to agreement.
• Proof that no petition has been filed on that FPA.
• Contact details for the PR or designated individual.

Common mistakes and how to avoid them

Form 15057 looks deceptively simple: two pages, four short paragraphs, and four signature fields. The recurring failure pattern is procedural rather than technical. Below are the mistakes I see most often when a BBA partnership routes a rescission package to my desk.

Workflows that keep your team calm

If you have ever lived through busy season while managing an FPA, you know delivery breaks when files are inconsistent or review loops pile up. A simple playbook helps:

• Standardize file names and version control for FPA packages.
• Use a one‑page “rescission readiness” checklist so a senior can confirm the statute, signatures, and attachments in one pass.
• Log the exact date your modification request was complete, the date the FPA mailed, and the default date.
• Keep the IRS contact’s details on the cover memo and submit to that attention line, as the form instructs.

Where Accountably fits, briefly

If your firm is short on capacity, bring in help for the prep work, not just the hours. The goal is disciplined delivery, tight workpapers, and predictable turnaround. Accountably integrates trained offshore teams into your workflow and tools, with SOPs, structured workpapers, and multi‑layer review so your partners spend less time chasing files and more time making decisions. Use outside capacity to build control, not chaos.

Step‑by‑step, with a sample cover memo outline

• Subject line that cites the partnership, EIN, tax year, and the FPA date.
• One paragraph stating the reason rescission is appropriate, for example, corrected facts or agreed procedural issue.
• A short bullet list of attachments, including Form 15057, the original FPA, supporting schedules, and proof that no petition has been filed.
• A closing line that requests countersignature and provides PR and practitioner contact information.

Keep it short, specific, and easy to scan. Your goal is to make the countersignature a straightforward decision.

Example timeline to track

• Day 0, FPA mailed.
• Day X, you and the IRS agree rescission is appropriate.
• Day X plus 1, Form 15057 signed by PR or designated individual and sent to the IRS contact named on the FPA.
• IRS review, letters prepared, and countersignature obtained before the FPA default date under IRM procedures.

Download links and version control

Always pull Form 15057 from the IRS PDF directory or the live IRS forms index. Confirm you see “Form 15057 (2‑2019)” at the top of page 1 and the instruction page on page 2. Store the blank PDF in your controlled templates and archive the executed version in the client’s permanent file along with delivery proof.

The “What, How, Wow” recap

• What: Form 15057 is the two‑page agreement the IRS and the partnership sign to rescind an issued FPA. It is current as of December 18, 2025.
• How: The PR or designated individual signs and submits it to the IRS contact named on the FPA, with clear support and precise identification, before the statute closes.
• Wow: Recent case law puts real teeth in §6235 timing. Good tracking and disciplined documentation give you leverage to resolve an FPA efficiently without litigation.

Operationalizing rescissions inside your firm

If your team is buried in production, rescissions can slip, and that is how deadlines get missed. Treat Form 15057 packages like mini projects.

• Assign a single owner, usually the senior reviewer, to run the checklist.
• Put the statute and default dates in the file name and on the cover page.
• Standardize naming, for example, 15057_Partnership_EIN_YYYY.pdf, to prevent version mix‑ups.
• For multi‑state groups, add a one‑page schedule of reviewed‑year partner impacts so reviewers do not hunt through workpapers.

If you need extra hands, bring in help that can operate inside your tools, follow your SOPs, and keep your reviewers protected. Capacity without structure is risky. The win is predictable turnaround and clean workpapers that shorten review time.

Compliance note

This article is for general information, not legal or tax advice. Partnership audit rules are technical and time sensitive. Confirm current procedures, case law, and facts with your advisor. For authoritative details, always review the current IRS form and the Internal Revenue Manual sections that govern FPAs and Form 15057 handling.

Final word

If an FPA does not match the facts or the process, you have a clean fix. Use Form 15057, get the right signature, submit to the contact named on the FPA, and keep your dates tight. A little discipline now saves weeks of rework later and keeps your team focused on client strategy instead of file chasing.

Reusable Checklists

These three checklists are written so a senior reviewer can paste them straight into a firm SOP for any BBA partnership routing a Form 15057 package. Each list maps directly to the Form 15057 instructions and the surrounding IRC §6231(d), §6234, and §6235 procedure.

Keep 15057 Season From Stalling

Form 15057 lands in a workflow the moment a BBA partnership forwards a final partnership adjustment letter from IRS Exam, and the rescission window is short. Per the Form 15057 instructions, two gates must hold open before the agreement is even available: the §6235 period of limitations on partnership adjustments must not have expired for the audited taxable year, and the partnership must not have filed a petition contesting the FPA in the U.S. Tax Court, the U.S. Court of Federal Claims, or a U.S. District Court.

The execution risk here is procedural, not technical. The form itself is two pages, but a misstep on who signs, when, or where the executed form is routed turns a clean rescission into a missed window – and the §6234 right to challenge that specific FPA is gone the moment the rescission takes effect.

• Confirm the partnership representative on file for the audited taxable year before circulating the form; only that PR – or the designated individual, if the PR is an entity – may sign Paragraph 1, not a general partner, tax matters partner, or outside counsel.
• Run the §6235 limitations clock against the taxable year shown on the FPA before drafting Paragraph 2; if the period has closed, the rescission is not available, and a §6235 extension may need to be papered alongside the rescission.
• Verify Paragraph 4 truthfully with counsel: confirm no Tax Court, Court of Federal Claims, or District Court petition has been filed contesting the imputed underpayment, since the affirmation cannot be made once any of those petitions is on the docket.
• Address the executed form to the contact person and IRS office named on the FPA itself, not a generic service center, Appeals office, or fax inbox; the form is routed to the named examiner, not centrally docketed.
• Track the IRS Official's countersignature date as the effective date of the rescission and update the audit calendar for any reissued FPA the Commissioner may later send, which can be higher, lower, or equal to the original adjustment amount.

We run this kind of audit-cycle execution inside our tax services workflow, with documented PR-of-record checks, §6235 calendar entries, and a structured handoff so the signed Form 15057 reaches the named IRS contact within the rescission window.

FAQs

Is it FPA or NFPA?

FPA is short for Final Partnership Adjustment; the full notice document is the Notice of Final Partnership Adjustment. The IRS uses FPA in its Internal Revenue Manual and on Form 15057, so using FPA in your filings and memos aligns with IRS terminology.

Can I use Form 15057 after filing a Tax Court petition?

No. Form 15057 requires that no petition has been filed on the FPA you want to rescind. If you already petitioned, work with counsel on litigation strategy instead.

Where do I send the form?

Submit the completed and signed form to the IRS office, attention to the contact person listed on your FPA. Keep proof of delivery and retain a copy in your permanent file.

Does rescission restart the statute?

Rescission returns both parties to pre‑FPA status. The IRS may issue a new FPA later if the statute remains open under §6235. Track dates carefully, especially in light of recent case law on timing.