IRS Form 15288 – Explained: Revoking a §6221(b) Election

Editorial Standards

How we research, review, and update this guide

Every Accountably guide is researched against primary IRS sources, reviewed by a U.S. CPA, and refreshed as guidance evolves. Read our Editorial Guidelines to see how we source, fact-check, and update our content.

A partnership elected out of the BBA centralized audit regime on a timely return, then Letter 2205-D shows up and the exam math now favors having those rules apply. Form 15288 is how you ask the IRS for permission to revoke that earlier election, because once a valid election out is made, you cannot undo it on your own.

The form gives you two mutually exclusive boxes, and you check only one. Box A revokes a prior election out under Section 6221(b); Box B revokes an early opt-in under Section 1101(g)(4) of the Bipartisan Budget Act of 2015. File within 30 days of receiving Letter 2205-D, attach Form 8979 for a Box A revocation, and work from the October 2022 revision.

Key Takeaways

• Form 15288 (Rev. October 2022) is the Request to Revoke Partnership Election under IRC Section 6221(b) or Request to Revoke Election under 1101(g)(4). It revokes a prior choice about the BBA centralized audit regime, not the BBA itself.
• Box A revokes a prior election out of the BBA under IRC Section 6221(b). Box B revokes an early opt-in election under Section 1101(g)(4) of the Bipartisan Budget Act of 2015.
• Revoking either election requires IRS consent. A partnership cannot revoke unilaterally; the request must be made within 30 days.
• Box A applies to partnerships with tax years beginning after 12/31/2017. Box B applies to tax periods that began after November 2, 2015 and before January 1, 2018.
• The election out under Section 6221(b) is made on a timely filed Form 1065 with Schedule B-2 partner details. The IRS typically notifies a partnership of an examination through Letter 2205-D.
• If a revocation is approved for a Section 1101(g)(4) opt-in, TEFRA or deficiency procedures apply as appropriate. A partnership representative is designated or revoked on Form 8979.

What Form 15288 Actually Does

Let’s clear up a common misconception. Form 15288 does not revoke the BBA itself. It revokes your prior choice about the BBA.

• If you originally elected out under section 6221(b) on a timely filed return and now want the BBA to apply for that tax year, you use Form 15288 to request consent to revoke that election out. The form text says exactly that.
• If you used section 1101(g)(4) to opt into BBA early for a tax period that began after November 2, 2015 and before January 1, 2018, you can request consent to revoke that earlier opt in. If approved, TEFRA or deficiency procedures will apply as appropriate.

Why does this exist at all? Treasury’s final regulations require IRS consent to revoke because unilateral revocations could distort statutes of limitations and complicate administration. That policy choice is laid out in preamble discussion and codified in 26 CFR 301.6221(b)-1.

Who Should Use Form 15288

Use this form if all of the following are true for the tax year under exam:

• Your partnership made a valid election out of the BBA under section 6221(b) on a timely filed return. The election out is made on Form 1065 and requires Schedule B-2 partner details.
• The IRS has notified you of an examination for that tax year, usually through Letter 2205-D.
• You want the centralized BBA regime to apply for that year, so adjustments, penalties, and collections occur at the partnership level, not through partner-level deficiency procedures.

Do not use this form if you never made a section 6221(b) election out, or if you are trying to make or validate an election out for the first time. Elections out are made on a timely filed return with the required partner disclosures, not on Form 15288.

At‑a‑Glance Use Cases

Case	What happened	What you ask for on Form 15288	If IRS approves
You elected out under §6221(b) on a timely filed 1065 and now received Letter 2205-D	Exam opens and you want BBA to apply	Revoke prior election out under §6221(b) and designate a PR on Form 8979	BBA regime applies for that year
You opted into BBA early under §1101(g)(4) for a 2016 or 2017 period	You now want TEFRA or deficiency procedures to apply	Revoke the prior §1101(g)(4) election	TEFRA or deficiency procedures apply, as appropriate

Source references, form text, and IRM procedures control these outcomes.

Where To Get The Form

• Official source, preferred for filing accuracy, is the IRS PDF, Form 15288, revision October 2022. It is a two-page fillable file that includes line-by-line instructions on page 2.
• Third-party libraries, such as TemplateRoller, also host the form and clearly note their sitewide legal disclaimer. Use these only when you cannot access IRS.gov, and always confirm you are using the current IRS revision.

Note on freshness: the IRS “Elect out” guidance page was reviewed July 2, 2025 and still reflects the current approach to section 6221(b) elections and their validity. This page, while not a filing instruction for revocations, frames eligibility and what a valid election out looks like.

How The Election Out Works, So You Know What You Are Undoing

You make an election out of the BBA on a timely filed Form 1065 by answering the election question on Schedule B and by attaching Schedule B-2 that lists every partner and, where applicable, S corporation shareholder details. The election is valid unless the IRS later determines it is invalid. It cannot be revoked without IRS consent.

Why you might want to revoke the election later:

• Partner-level deficiency procedures can create dozens of assessments and notices, which can be messy for multi-partner groups.
• BBA centralizes adjustments at the partnership and can simplify collections and penalty administration for a single year under exam.
• The IRS may invite a revocation during early exam discussions to streamline resolution.

These are practical, not promotional, considerations. Your partnership agreement, PR authority, and investor relations all matter here.

The Step‑By‑Step Filing Sequence

1) Confirm You Are Eligible To Revoke

• Verify a valid election out exists for that tax year. Check your filed Form 1065, the Schedule B election question for that year, and the presence and accuracy of Schedule B-2.
• Confirm you are now under examination for that same tax year and that Letter 2205-D names an IRS contact.

2) Calendar The 30‑Day Window

• You generally have 30 days from receipt of Letter 2205-D to submit Form 15288 to the person named in that letter. Set a hard internal deadline and track delivery. The IRM allows acceptance after 30 days only in limited, administratively convenient cases.

3) Prepare Form 15288 And Form 8979

• Open the IRS PDF for Form 15288, complete the header, check the correct box for the type of revocation, and finish the signature blocks. Page 2 instructions specify who must sign, based on which election you are revoking.
• If you are revoking a section 6221(b) election out, you must designate a Partnership Representative using Form 8979 and include it with your request.

4) Submit To The IRS Contact On Letter 2205‑D

• Mail or submit Form 15288 to the individual named on Letter 2205-D. This is not an e-file attachment to a return. It is an exam-stage submission to the assigned IRS contact. The IRM spells this out.

5) Document Acceptance And Next Steps

• If the examiner accepts the revocation, management approval is recorded and the case is updated to reflect BBA applicability. The IRM describes how the IRS updates its systems and may give you 30 days to file a BBA AAR before issuing NAPs. Capture every timestamp and keep copies.

Signatures, Authority, And Roles

• If you are revoking an election out under section 6221(b), any person authorized to sign Form 1065 can sign Form 15288, for example a partner or LLC member.
• If you are revoking a prior 1101(g)(4) opt in, the partnership representative or designated individual signs – not any partner or LLC member, since Box B signature requirements are stricter than Box A.
• If a trustee or DIP signs, include the court order authorizing the signing. That requirement appears on page 2 of the form instructions.

What The IRS Looks For

Examiners will validate that your Form 15288 was timely, signed by someone authorized, and includes required information. They will also confirm PR designation via Form 8979 and then adjust internal codes so the BBA regime applies if accepted. The IRM details these checkpoints.

Practical tip: keep your schedules, authority documentation, and PR confirmation in one digital packet with clear naming conventions. If your firm spans multiple entities or states, version control and access logs save hours during review.

What To Include In Your Package

Core Documents

• Completed Form 15288 for the specific tax year under exam. The form is year specific and cannot cover multiple years.
• Form 8979 to designate your Partnership Representative if you are revoking a section 6221(b) election out.
• A brief cover letter that states the date you received Letter 2205-D, the date you are submitting your revocation request, and a one-paragraph rationale.

Supporting Evidence

• Copy of the originally filed Form 1065 showing the election out question, plus Schedule B-2. The IRS “Elect out” page and regs explain what a valid election out includes, so these help the examiner confirm your starting point.
• Proof of authority to sign, such as excerpts from the partnership agreement or state filings, if there is any ambiguity.
• Delivery proof. Keep certified mail or upload confirmations, as well as email threads if you coordinate submission through secure channels.

Common Mistakes To Avoid

These checklists are copy-paste ready for firm SOPs. Drop them into your exam-response playbook, your peer-review template, or your engagement workspace and tick items as you go.

Quick Reference, Straight From The Sources

Topic	What the source says	Source
How to make a valid election out	Do it on a timely filed 1065, answer the Schedule B question, and attach Schedule B-2 with partner information.	IRS “Elect out” page, reviewed July 2, 2025.
Can you revoke without consent	No. Revocation requires IRS consent.	Final regs and preamble discussion.
What Form 15288 is for	Request to revoke a §6221(b) election out or an early opt in under §1101(g)(4).	IRS PDF, Rev. 10‑2022.
Timing after Letter 2205‑D	Submit within 30 days to the person named in the letter.	IRM 4.31.9 procedures and form instructions.
What happens if accepted	BBA applies, and the group may grant 30 days to file a BBA AAR before NAPs.	IRM 4.31.9.7.5.1 and 4.31.9.7.4.1.

Access And Version Control

The form is officially hosted on IRS.gov as f15288.pdf, a two-page PDF revised October 2022 with instructions on page 2. Third-party libraries like TemplateRoller also host the file and label it as valid for recent years with a clear disclaimer. When you download from a third-party site, confirm the revision date and compare against the IRS copy. Store both the editable PDF and a flattened, read-only copy in your workpapers.

Trust signal for your files: keep the IRS PDF checksum or at least record the file size and revision date in your retention notes. It helps if someone later questions whether you used the right form.

Practical Workflow You Can Follow Today

Prep

• Pull your originally filed Form 1065 and Schedule B-2 for the year under exam. Validate eligibility for the prior election out.
• Identify who is authorized to sign. If authority is not clear, fix that before you touch the form.
• Open Form 15288 from IRS.gov, confirm it is the Rev. 10‑2022 two-page PDF.

Complete

• On page 1, enter partnership info, check box A if you are revoking a §6221(b) election out, or box B if you are revoking an early opt in under §1101(g)(4) – check only one box, since the two are mutually exclusive and checking both invalidates the request.
• Add Form 8979 to designate your PR if you checked box A.
• Sign and date in the correct signature block based on which election you are revoking.

Submit

• Send the packet to the IRS person named on Letter 2205-D within 30 days of receipt. Use tracked delivery and retain proof.
• Log the submission in your case tracker and alert stakeholders that BBA may soon apply, which affects downstream actions like a potential BBA AAR.

After Acceptance

• Watch for the acceptance notice. If granted, the examiner may provide a 30-day window for you to file a BBA AAR. Plan partner communications and cash impacts accordingly.
• Verify the IRS updated exam codes to reflect BBA applicability. Your examiner will handle the internal forms, but you want this noted in your file.

How Accountably Can Help, Briefly

If your team is already stretched on compliance, the mechanics of pulling prior-year evidence, preparing Form 15288, producing Form 8979, and organizing delivery proofs can eat days. Our teams at Accountably build disciplined delivery routines that keep your workpapers standardized, your signatures and PR documentation current, and your submission logs complete. We work inside your systems, enforce SOPs, and reduce review loops, so partners spend less time chasing files and more time on strategy. Use us when you need capacity with structure and audit-ready documentation, not just resumes.

That is all you need to know about us here. The rest of this guide stays focused on helping you get this done well.

Compliance, Security, And Recordkeeping

• Keep the signed Form 15288, Form 8979, Letter 2205-D, delivery proof, and any IRS acceptance in one indexed folder with access controls and audit logs.
• Retain both editable and flattened PDFs. Note the IRS form revision and the date you accessed it.
• For teams that handle sensitive partner data as part of Schedule B-2 support, lock down role-based access and maintain zero local storage for tax data.
• Add a short memo that explains why you chose to revoke the election and list the dates that drive your timeline.

Quick reminder: nothing in this article is legal or tax advice. You should confirm facts with your own counsel and advisors. Always read the governing IRS materials yourself.

Final Checklist You Can Paste Into Your Workflow

• Confirm valid election out exists for the year under exam, with Schedule B-2 on file.
• Record the date you received Letter 2205-D and set a 30-day submission timer.
• Complete Form 15288, select the correct revocation box, and sign in the right block.
• Attach Form 8979 to designate your PR for a §6221(b) revocation.
• Send to the IRS person named on Letter 2205-D, track delivery, and retain proof.
• Watch for acceptance, note any 30-day AAR window, and align your next steps.

Sources You Can Trust

• IRS, Form 15288 PDF, Rev. 10‑2022. This is the controlling form and includes page 2 instructions.
• IRS, Elect out of the centralized partnership audit regime, page last reviewed July 2, 2025. Useful for understanding what a valid election out looks like.
• 26 CFR 301.6221(b)-1, revocation requires consent.
• IRM 4.31.9 examination procedures, including timing, who to send to, and post-acceptance workflow.
• TemplateRoller hosting page, with disclaimer, if you need a mirror download. Always verify against IRS.gov.

Closing Thought

You are not fighting a sales problem in your firm. You are fighting delivery friction during high-stakes work. With a calm process, the right files, and the right people focused on the right steps, Form 15288 becomes a straightforward request for consent, not a fire drill. Anchor your timing, document authority, submit cleanly, and keep moving. If your team needs structured help on the mechanics, bring in disciplined support so partners can stay focused on decisions, not document chases.

Reusable Checklists

Form 15288 does not run on a calendar season. It runs on Letter 2205-D. When that examination notice lands, the partnership has 30 days to file a revocation request, designate or confirm a Partnership Representative, attach Form 8979 if Box A applies, and route the package to the IRS contact named on the letter (per the IRS Form 15288 instructions, October 2022 revision). The 30-day window is the bottleneck, not workload volume.

The fix is not more hours during exam. It is a pre-built response packet so the clock does not start with a scramble. Once Box A workflows (revoking the §6221(b) opt-out) are separated from Box B workflows (revoking the §1101(g)(4) early opt-in), most of the work becomes templated.

• Trigger a 30-day countdown task the day Letter 2205-D is logged, with a Day 10 internal review and a Day 20 sign-off target.
• Maintain a Box A template that attaches Form 8979 by default and routes signature to any authorized Form 1065 signer.
• Keep a Box B template that routes signature to the partnership representative or designated individual only – the signer rule is stricter than Box A.
• Validate that exactly one box is checked before the package leaves your review queue – dual-box submissions invalidate the request.
• Address the envelope to the IRS contact named on Letter 2205-D, not a generic service center.

Teams that handle these revocations as part of a managed tax outsourcing engagement can preload the Box A and Box B templates, log the Letter 2205-D date the day it arrives, and keep the 30-day clock from becoming a fire drill.

Keep 15288 Season From Stalling

Form 15288 work does not run on a calendar. It runs on a clock. The Form 15288 instructions (Rev. October 2022) tie the revocation request to the date the partnership receives Letter 2205-D, the IRS notice that an examination has opened, and give the partnership 30 days to file the request with the person named on that letter. Miss that window and the IRS Internal Revenue Manual treats the late submission as discretionary, accepted only when it is administratively convenient for the Service. There is no quarterly cadence to plan around and no software queue to push the work into, only a thin time band that opens the day the letter lands in the partner's inbox.

FAQs

Is Form 15288 e‑filed with the partnership return?

No. In exam posture, you mail or submit Form 15288 to the IRS person named on Letter 2205-D, generally within 30 days. Do not rely on attaching it to an e-filed return. The form instructions and IRM address submission during exam.

We elected out under §6221(b). What changes if the IRS accepts our revocation?

If accepted, the BBA centralized partnership audit regime applies to that tax year. Examiners update their systems and may allow 30 days for a BBA AAR before issuing NAPs. Expect centralized adjustments at the partnership level instead of partner-by-partner deficiency procedures.

Who can sign Form 15288?

If you are revoking a §6221(b) election out, any person authorized to sign Form 1065 can sign, for example a partner or LLC member. If you are revoking a §1101(g)(4) opt in, the partnership representative or designated individual signs. Page 2 of the form lays this out.

Do we need a Partnership Representative for a §6221(b) revocation?

Yes. If you are revoking an election out, you must appoint a PR and include Form 8979 with your request. The form text and instructions are explicit on this point.

We missed the 30‑day window after Letter 2205‑D. Are we out of luck?

Not necessarily. The IRM says the Service may accept a revocation after 30 days in limited cases when it is administratively convenient. Document your reasons and submit promptly. Final acceptance is at the IRS’s discretion.

Does state conformity change automatically when we revoke?

Federal regime changes can influence state procedures, but each state has its own rules. Review conformity and audit processes for each jurisdiction and document the impact for your stakeholders.