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A partnership representative resigns mid-audit without notice, without filing anything, and without naming a successor. What follows is weeks of scrambling while the IRS keeps sending correspondence to someone no longer authorized to act. Form 8979 is the remedy for exactly that gap, and the BBA rules are not forgiving when a partnership ignores it.
Form 8979 is the Partnership Representative Designation or Resignation form that a BBA partnership uses to change, revoke, or resign its PR mid-cycle. In Part I you check Box 1 to designate or revoke, which automatically revokes any prior designation, or Box 2 to resign. The initial PR designation still happens on Form 1065, not here. This revision carries the Rev. September 2025 stamp.
Key Takeaways
- What it does: Form 8979 is used to revoke a partnership representative (PR) designation, notify the IRS of a PR resignation, or designate a new PR mid-cycle, separate from the annual Form 1065 designation.
- Who files it: The partnership itself (for revocations and new designations) or the outgoing partnership representative (for resignations), filed directly with the IRS.
- Key restriction: Form 8979 is reserved for mid-cycle PR changes, revocations, and resignations – it is not used for annual partnership representative designations on Form 1065, which happen through a different mechanism.
- Revocation is automatic: Checking Box 1 in Part I to designate a new PR automatically revokes any prior designation for that tax year – no separate IRS consent is required.
- Successorship gap risk: If a PR resigns or is revoked before a successor is designated, the IRS may proceed with the audit without a valid PR in place, and the partnership may lose its ability to participate effectively.
- SOP tip: Any partnership subject to BBA rules should have a PR succession plan documented in its partnership agreement – Form 8979 is the remedy when that plan was never made.
What Form 8979 Is and When to Use It
Under the BBA centralized partnership audit regime (effective for tax years beginning after December 31, 2017), every partnership subject to the BBA rules must designate a partnership representative. The PR is the sole authority for the partnership in IRS audit proceedings – partners have no independent right to participate. The PR can bind the partnership on all audit matters, including settlements, election of push-out, and acceptance of Final Partnership Adjustments.
Form 8979 exists because circumstances change during audits. A PR may resign, become incapacitated, or lose the partnership’s confidence. The partnership may need to revoke the designation. The IRS needs a way to formally process these changes and ensure there is always a valid PR in place to receive IRS notices and bind the partnership.
When Form 8979 Is Needed
Three triggering events require Form 8979:
- Revocation by the partnership: The partnership wants to remove the current PR and designate a new one. Checking Box 1 to designate the successor automatically revokes the prior designation; no separate IRS consent is required.
- Resignation by the PR: The current PR wants to resign from the role. The form notifies the IRS and should be accompanied by a designation of the successor PR.
- Designation of a new PR: After a revocation or resignation (or when no valid PR exists due to a prior gap), the partnership designates a new PR using Form 8979.
What Form 8979 Is NOT Used For
Form 8979 is not used for the initial designation of a partnership representative on the partnership’s annual return (Form 1065 – the PR designation there happens in the relevant section of the return itself). It is also not used to make the initial BBA election. Form 8979 is the tool for changing, revoking, or documenting the resignation of a PR or DI mid-cycle, separate from the annual Form 1065 designation.
The Designated Individual Requirement
If the designated PR is an entity (not a natural person), the partnership must also designate a specific “designated individual” who will act as the PR’s human contact point with the IRS. When an individual (not an entity) is the PR, by contrast, there is no designated individual, and the form’s Part II note directs you to leave the designated-individual lines blank. Both the entity PR and the designated individual must be identified on Form 8979. This requirement catches some practitioners off-guard when the partnership’s managing entity – an LLC or GP entity – is named as PR without identifying the human representative.
How to Complete Form 8979, Section by Section
Form 8979 is relatively concise – a two-page form – but each section requires precise information to be processed correctly by the IRS during an active audit.
| Section / Field | What to Complete | Practitioner Notes |
|---|---|---|
| Part I – Reason for Filing | Check Box 1 (the partnership is designating a PR or DI, which revokes any prior designation) or Box 2 (the PR or DI is resigning) – exactly one box | Check only one box. Box 1 routes you to Part II and Part IV, Section A; Box 2 routes you to Part III and Part IV, Section B. The partnership name, EIN, and tax year ending go in the form header, not Part I. |
| Part II – Designation and/or Appointment by the Partnership | Name and TIN of the PR being designated; if the PR is an entity, also the designated individual’s name and TIN | Complete this Part for a designation (Box 1). Leave the designated-individual lines blank when an individual PR is named; complete them only for an entity PR. |
| Part III – Resignation | Identify the resigning PR or DI: name, TIN, and a U.S. street address and U.S. telephone number (Part III does not accept a foreign address) | Part I has only two boxes and they are mutually exclusive – check exactly one (Box 1 to designate/revoke, Box 2 to resign). A resignation, however, cannot be bundled onto the same Form 8979 as a designation – the resigning party must file a separate Form 8979 with its own Part I box checked and its own signature section. Do not leave the action ambiguous. |
| Part IV – Signature Section | Sign Section A for a designation/revocation (an authorized person, under penalties of perjury) or Section B for a resignation (the resigning PR or DI) | The new PR’s TIN is required – do not submit without it. For entity PRs, include both the entity EIN and the designated individual’s SSN or ITIN. |
| Signatures | Signed by the partnership representative, a partner, or other authorized person per the applicable action (the Section A signer must be someone duly authorized by the partnership or LLC under penalties of perjury, and an entity signer must be able to legally bind that entity under applicable state law – not just any partner) | For revocations: the partnership must sign. For resignations: the outgoing PR must sign. For new designations: an authorized person who can bind the partnership signs Part IV, Section A – not the new PR. Missing signatures cause IRS rejection. |
Where to File Form 8979
Form 8979 is filed directly with the IRS – specifically with the IRS office or agent handling the partnership audit, not with a general IRS filing center. The form should be sent to the address or fax number provided in the audit notification correspondence. Always retain a copy and confirm receipt with the IRS agent in writing.
How a Revocation Takes Effect
A key point on mechanics: a revocation does not require IRS consent. Checking Box 1 in Part I to designate a new PR automatically revokes any prior designation for that tax year by operation of the form. My practice is to always accompany a revocation request with the designation of a successor PR to eliminate any concern that the audit will be left without an authorized representative.
Deadlines, Filing Requirements, and Consequences
Form 8979 has no fixed annual filing deadline – it is an event-driven form filed when a PR or DI change occurs mid-cycle. But the practical deadlines are driven by the audit timeline.
| Event | Timing | Consequence of Delay |
|---|---|---|
| PR resignation during audit | As soon as the PR decides to resign; should not wait until IRS correspondence arrives | IRS continues to send binding notices to the outgoing PR; any actions taken by the outgoing PR after resignation intent is formed remain legally binding on the partnership |
| Revocation request by partnership | File when the partnership decides to replace the PR; designating the successor on Form 8979 automatically revokes the prior designation | Until the new designation is filed, IRS communications continue to the PR on file and bind the partnership |
| Designation of successor PR | Simultaneous with or immediately after revocation or resignation | A gap without a valid PR leaves the IRS without an authorized contact and may allow the IRS to proceed without the partnership’s participation |
| Final Partnership Adjustment issuance | IRS issues to the PR on file at the time of issuance | An FPA issued to a former or unauthorized PR may still bind the partnership; strict compliance with Form 8979 timing prevents this dispute |
What Happens Without a Valid PR
If a partnership fails to maintain a valid partnership representative during an audit, the IRS has authority to select a PR from among the partnership’s partners. The IRS-appointed PR has the same authority as a voluntarily designated one – including the ability to waive rights and bind the partnership. This is an outcome every partnership should be motivated to avoid.
The Partnership Representative Role: Authority, Liability, and Strategy
The partnership representative is one of the most consequential roles in the BBA audit framework. Understanding its scope is essential before designating someone to fill it.
Sole Authority to Bind the Partnership
The PR has the exclusive authority to act on the partnership’s behalf in an IRS audit proceeding. No partner – regardless of ownership percentage or governance rights under the partnership agreement – has an independent right to participate in the audit, review correspondence, or challenge actions taken by the PR. The PR’s decisions are binding on the partnership and all its current and former partners for the reviewed year.
Eligibility Requirements for Partnership Representatives
A PR must have “substantial presence” in the United States – the IRS defines this as being available to meet with the IRS in the U.S., having a U.S. taxpayer identification number, and having a U.S. address and phone number. A PR can be any person, including a non-partner – the firm’s CPA is a common and appropriate choice. Entity PRs must designate a designated individual who meets the same presence requirements. This eligibility check should be conducted before the initial Form 1065 designation, not just when Form 8979 is needed, because designating a PR who lacks substantial U.S. presence can invalidate the designation and expose the partnership to an IRS-selected representative.
Strategic Considerations When Changing the PR
Changing the PR mid-audit is not just a procedural formality. The new PR inherits all prior audit history and is bound by any actions the prior PR already took – including representations made to the IRS agent, documents provided, and any informal settlements in progress. Before accepting the PR designation on Form 8979, the new PR should review all prior audit correspondence, confirm the status of any open issues, and assess what has already been conceded. From my side of the desk, I always run a full audit file review before signing onto a PR role mid-proceeding.
Form 8979 in the Context of BBA Partnership Audit Administration
Form 8979 connects to a larger ecosystem of BBA-related forms and procedures. Understanding how it fits helps practitioners advise partnership clients comprehensively.
Related BBA Forms
Form 8979 relates closely to Form 8983 (Certification of Partner Tax-Exempt Status for Modification under IRC §6225(c)(3)) and Form 8978 Schedule A (Partner’s Additional Reporting Year Tax). Together, these forms manage the administrative infrastructure of BBA audits – who speaks for the partnership, and how the audit’s tax consequences are allocated to partners. Form 8989 (Request to Revoke the Election for Alternative to Payment of the Imputed Underpayment) also connects to the broader BBA compliance system.
Impact on Partnership Governance Documents
The BBA regime exposed a significant gap in many partnership agreements: they either failed to address the PR role at all or addressed it in ways incompatible with the BBA’s requirements. After the BBA became effective, practitioners scrambled to update partnership agreements to specify PR designation procedures, succession plans, and partner rights to indemnification if the PR’s actions result in partnership-level tax payments that fall on current partners for prior year adjustments. Form 8979 is often the symptom – the fix is in the partnership agreement.
Common Mistakes That Slow Things Down
The same handful of errors show up on nearly every Form 8979 I review, and each one stalls the filing while the IRS exam clock keeps running. Build these into your tax review checklist so they never reach the IRS.
Practical Checklists You Can Reuse
These checklists are copy-paste ready for your firm SOPs. Drop them into your workpaper template so every Form 8979 filing follows the same path, whether you are designating, revoking, or documenting a resignation.
Designate or revoke a partnership representative
- Confirm the partnership is under the BBA regime (tax years beginning after December 31, 2017).
- Check Box 1 in Part I (Reason for Filing); a new designation automatically revokes any prior one for that tax year.
- Enter the partnership EIN and tax year ending (mm/dd/yyyy) in the header.
- Complete Part II with the new PR’s name and TIN.
- If the PR is an entity, add the designated individual and their TIN; if the PR is a person, leave the DI lines blank.
- Verify substantial U.S. presence for the PR and any DI under IRC §6223.
- Have an authorized person sign Part IV, Section A under penalties of perjury; for an entity signer, print name and title.
- Check the AAR box only if filing with Form 8082 or Form 1065X.
Document a partnership representative resignation
- Check Box 2 in Part I (Reason for Filing) for a resignation.
- Complete Part III with the resigning PR or DI name and TIN.
- Provide a U.S. street address and U.S. telephone number; Part III does not accept a foreign address.
- Have the resigning PR or DI sign Part IV, Section B in person.
- File a separate Form 8979 to name the successor; the partnership has 30 days to designate one before the IRS may step in (per Treas. Reg. §301.6223-1).
- Keep a dated copy and confirm IRS receipt in writing.
Substantial U.S. presence verification
- Confirm the proposed PR has a U.S. taxpayer identification number.
- Confirm a U.S. street address and a U.S. area-code phone number.
- Confirm availability to meet with the IRS inside the United States.
- For an entity PR, run the same three checks on the designated individual.
- Document the result in the engagement file before completing Part II.
Keep 8979 Season From Stalling
Form 8979 rarely arrives on a schedule. A partnership representative resigns in the middle of a BBA exam, a managing entity gets dissolved, or an agent flags that the PR on file no longer has substantial U.S. presence. The centralized partnership audit regime, effective for tax years beginning after December 31, 2017 under the Bipartisan Budget Act of 2015, gives the partnership only 30 days to name a successor after a resignation before the IRS can designate one for you (per Treas. Reg. §301.6223-1).
That short window is where most filings stall. The fix is to treat every PR change as a defined workflow with one owner, not a scramble across email threads. When the intake template already knows which Part and signature block each action needs, the form goes out clean the first time.
- Route every request through Part I first: Box 1 for a designation or revocation, Box 2 for a resignation, never both on one form.
- Pair each action with its signature block, Part II with Part IV Section A for designations, Part III with Part IV Section B for resignations.
- Verify substantial U.S. presence (U.S. TIN, address, and phone) for the PR and any designated individual under IRC §6223 before anyone signs.
- Complete the designated-individual lines in Part II only when an entity is the PR, and leave them blank for an individual PR.
- Check the AAR box only when the form is filed with Form 8082 or Form 1065X.
This is the kind of structured, documented execution we build for partnership filings at Accountably. Our tax outsourcing teams run PR changes through standardized workpapers and a multi-layer review, so the 30-day clock never catches you mid-audit.
FAQs
What is Form 8979 used for?
Form 8979 is used to revoke a partnership representative designation, notify the IRS of a partnership representative’s resignation, or designate a new partnership representative mid-cycle, separate from the annual Form 1065 designation. It is not used for the annual PR designation on Form 1065, which happens directly on the partnership return.
When can a partnership revoke a partnership representative?
A partnership can change its partnership representative by filing Form 8979 to designate a successor; checking Box 1 in Part I automatically revokes any prior designation for that tax year. No separate IRS consent is required for the revocation to take effect. Revocations must generally be accompanied by the designation of a successor PR to avoid leaving the audit without an authorized representative.
Does a partnership representative have to be a partner?
No. A partnership representative can be any person – including a non-partner such as the partnership’s CPA or attorney – as long as they have “substantial presence” in the United States. This means a U.S. taxpayer identification number, a U.S. address, a U.S. telephone number, and availability to meet with the IRS in person in the U.S. Entity representatives must also designate a specific human “designated individual.”
What happens if a partnership has no valid partnership representative during an audit?
If a partnership fails to maintain a valid partnership representative during a BBA audit proceeding, the IRS has authority to designate a PR from among the partnership’s current partners. The IRS-appointed PR has the same broad authority as a voluntarily designated one, including the ability to bind the partnership and all its partners on all audit matters. Avoiding this outcome is a primary motivation for filing Form 8979 promptly when a PR change is needed.
Can the partnership representative resign during an audit?
Yes. A partnership representative can resign during a BBA audit by filing Form 8979 with the IRS. The resignation should be accompanied by a designation of a successor PR. The outgoing PR remains authorized until the IRS formally acknowledges the resignation, so the outgoing PR should avoid taking additional actions on behalf of the partnership after submitting the resignation form.