1. Introduction: What is Form 15288?

IRS Form 15288, officially titled Request to Revoke Partnership Election under IRC Section 6221(b) or Request to Revoke Election under 1101(g)(4), is an administrative tax election form published by the Internal Revenue Service (IRS). It is governed by the centralized partnership audit regime created under the Bipartisan Budget Act of 2015 (BBA), administered by the IRS Small Business/Self-Employed (SB/SE) and Large Business & International (LB&I) Divisions.

This form is not a standard annual tax return that partnerships file with their yearly Form 1065. Instead, Form 15288 is a specialized legal petition used by partnerships undergoing an IRS audit to request formal IRS consent to undo a prior election regarding the BBA audit regime. It allows eligible small partnerships to revoke an earlier election out under Internal Revenue Code (IRC) Section 6221(b), bringing them into centralized partnership audit rules, or to revoke an early opt-in election under Section 1101(g)(4).

2. Purpose of the Form: Why Does Form 15288 Exist?

Under the BBA centralized partnership audit regime, the default statutory rule is that the IRS audits partnerships and assesses taxes directly at the entity level. However, under Section 6221(b), an eligible small partnership (one with 100 or fewer qualifying partners, such as individuals, C corporations, and S corporations) can elect out of these centralized rules on a timely filed return using Schedule B-2. When a partnership elects out, any future audit must be conducted separately against each individual partner under traditional deficiency procedures.

Under IRC Section 6221(b)(1)(E), once a partnership makes an election out of the BBA, that election cannot be revoked without the consent of the IRS. Form 15288 exists to provide the formal mechanism to petition the IRS for that consent, solving major procedural challenges when an audit begins:

Unifying Fragmented Partner Audits: When the IRS audits a partnership that elected out, every single partner faces separate IRS examination letters, independent representation costs, and conflicting statute of limitations deadlines. Form 15288 allows the partnership to pull the audit back to the entity level.
Unlocking Centralized BBA Settlement Tools: By revoking the opt-out, the partnership gains access to BBA settlement procedures—such as appointing a single Partnership Representative (PR), filing an Administrative Adjustment Request (AAR), requesting imputed underpayment modifications, or electing the Section 6226 “push-out” option.
Standardizing the Revocation Workflow: It provides a clear, uniform template for the partnership to state its business justification and designate a Partnership Representative under Form 8979.

3. Who Needs to File This Form?

Form 15288 is an entity-level document used exclusively by partnerships that previously made a formal BBA election. You need to file Form 15288 if:

Your partnership previously filed a valid election out of the BBA centralized audit regime under IRC Section 6221(b) on Schedule B-2 of Form 1065.
The partnership received IRS Letter 2205-D (Initial Partnership Examination Contact Letter) and determined that it is in the best interests of the partnership and its partners to be audited under the centralized BBA rules.
Your partnership previously made an early opt-in election under Section 1101(g)(4) for a tax period between November 2, 2015, and January 1, 2018, and now seeks to revoke that early election.
The partnership is submitting a formal request for IRS consent under Treasury Regulation Section 301.6221(b)-1.

4. Who Is Exempt / Not Required to File?

Large categories of businesses and partnerships have no reason to use Form 15288:

Partnerships That Never Elected Out: Partnerships that never filed Schedule B-2 are automatically governed by the BBA regime and do not file Form 15288.
Ineligible Partnerships: Partnerships with more than 100 partners, or partnerships that have trusts, disregarded entities, or other partnerships as partners, are legally ineligible to elect out under Section 6221(b) and cannot use this form.
Partnerships Content with Separate Audits: If a partnership made an election out and prefers to have each partner audited separately under standard deficiency rules, no revocation form is filed.
Individual Partners: Individual investors and partners never file Form 15288; the application must be executed by the partnership entity.

5. When to File: Deadlines and Frequency

Form 15288 is an event-based administrative petition rather than an annual recurring tax return. It carries a strict operational deadline governed by IRS audit procedures.

Under Internal Revenue Manual (IRM) 4.31.9.7.5 and Form 15288 instructions, if a partnership is under examination, Form 15288 must be submitted within 30 calendar days from the date the partnership receives Letter 2205-D (the initial exam notice). Meeting this 30-day window is essential: if submitted after 30 days, the IRS is not required to consider the request, and acceptance becomes entirely discretionary based on whether it is administratively convenient for the IRS audit team.

6. Where and How to File

Form 15288 cannot be submitted through consumer tax preparation software or attached to an annual e-filed Form 1065. It must be delivered directly to the IRS audit team:

Direct Submission to the Examiner: In an examination setting, submit the completed, signed Form 15288 directly to the IRS revenue agent or group manager named on your Letter 2205-D.
Submission Channels: The form can be transmitted via secure encrypted email, secure fax, or mailed directly to the examiner using the designated IRS address as per instructions on Letter 2205-D.
Mandatory Form 8979 Attachment: If you are revoking a Section 6221(b) election out (Box A), you must attach Form 8979 (Partnership Representative Revocation, Designation, and Resignation) to designate an official Partnership Representative. A Box A request submitted without Form 8979 is legally incomplete.
Certified Mail Recommended: If mailing, send your package via certified mail with tracking to establish verified proof of delivery within the 30-day window.

7. Step-by-Step Instructions to Fill Form 15288

Form 15288 is a concise, single-page application consisting of partnership identification, election revocation selection, and partner execution blocks. The table below outlines each section of the form.

Section	Field / Topic	Required Information & Instructions
Header	Partnership Details	Legal partnership name, Employer Identification Number (EIN), and tax year(s) under review.
Section I	Box A Selection	Checkbox to revoke prior election out under Section 6221(b) (requires attached Form 8979).
Section I	Box B Selection	Checkbox to revoke prior early opt-in election under Section 1101(g)(4).
Section II	Justification Narrative	Written explanation describing the business and administrative reasons for requesting revocation.
Section III	Partner Execution	Original signature of a partner or authorized representative, printed name, title, and date.

Part 1: Partnership Information

Enter the complete registered legal name of the partnership exactly as shown on its Form 1065. Provide the partnership’s nine-digit Employer Identification Number (EIN) and current business mailing address. In the tax period line, list the specific partnership taxable year or years under examination for which the revocation is requested.

Part 2: Selecting Box A or Box B (Mutually Exclusive)

Form 15288 provides two mutually exclusive options; you must check only one box:

Check Box A: Select Box A if the partnership previously elected out of the BBA centralized audit regime on Schedule B-2 under IRC Section 6221(b) and now wants to revoke that election and be governed by BBA audit rules. You must attach Form 8979 to designate your Partnership Representative.
Check Box B: Select Box B if the partnership previously made an early opt-in election under Section 1101(g)(4) of the Bipartisan Budget Act of 2015 and now seeks to revoke that early election.

Part 3: Explanation and Factual Justification

You must provide a clear written explanation detailing why the partnership is requesting revocation. Explain the administrative or practical advantages, such as simplifying the audit process, eliminating the burden of multiple individual partner examinations, or allowing the partnership to utilize centralized BBA settlement mechanisms.

Part 4: Partner Signature and Authorization

Form 15288 must be signed and dated by an authorized partner, member, or corporate officer of the partnership. Print the signer’s full legal name, official title, and direct daytime telephone number. If an outside attorney or CPA submits the form, a valid Form 2848 (Power of Attorney) must be attached.

8. Required Documents and Information Needed Before Filling

Before preparing Form 15288, assemble the following audit and tax records:

The original IRS Letter 2205-D received from the IRS examination team.
A copy of the originally filed Form 1065, including Schedule B-2 showing the original election out.
Form 8979: Partnership Representative Revocation, Designation, and Resignation (mandatory for Box A filers).
Legal identifying information (name, address, TIN, and phone number) for the proposed Partnership Representative and Designated Individual (if an entity PR is appointed).
A signed Form 2848 (Power of Attorney) if legal counsel or an accounting firm represents the partnership.

9. Common Mistakes to Avoid

Errors on Form 15288 can cause the IRS to reject your revocation request, leaving partners exposed to separate audits. Watch out for these frequent mistakes:

Checking Both Box A and Box B: Box A and Box B are mutually exclusive. Checking both boxes will result in an immediate rejection.
Forgetting to Attach Form 8979: Under BBA rules, a partnership governed by the centralized audit regime must have an active Partnership Representative. If you check Box A without attaching Form 8979, the IRS will reject the revocation as defective.
Missing the 30-Day Window: Failing to submit Form 15288 within 30 calendar days of receiving Letter 2205-D allows the IRS examiner to reject the request as untimely.
Attempting to E-File on an Original Return: Form 15288 cannot be attached to an e-filed Form 1065. It must be delivered directly to the IRS examination team handling the audit.
Assuming Revocation Is Automatic: Submitting Form 15288 does not automatically revoke the election. Revocation requires formal written approval from an authorized IRS Group Manager under Delegation Order 4-52.

10. Penalties for Non-Filing or Errors

Form 15288 is an optional administrative request, so there are no direct tax fines for not filing it. However, the procedural and financial consequences of failing to revoke an opt-out can be severe:

Multiple Individual Partner Audits: If your revocation request is denied or not submitted, the IRS will proceed with individual audits against every single partner, multiplying accounting fees, legal costs, and administrative burdens across your investor base.
Loss of BBA Settlement Protections: Without BBA rules, the partnership cannot resolve the audit through a single imputed underpayment, nor can it utilize the Section 6226 “push-out” election.
Statute of Limitations Discrepancies: In individual partner audits, different partners may have different open statute of limitations dates, leading to inconsistent tax treatment among partners.
Perjury Consequences: Form 15288 is signed under penalties of perjury. Falsifying partnership data or representations is punishable under 26 U.S.C. Section 7206.

11. Related Forms or Schedules

Form 15288 operates within an interconnected system of federal partnership taxation and BBA audit forms:

Form 1065: U.S. Return of Partnership Income.
Schedule B-2 (Form 1065): Election Out of the Centralized Partnership Audit Regime.
Form 8979: Partnership Representative Revocation, Designation, and Resignation (mandatory attachment for Box A).
IRS Letter 2205-D: Initial Partnership Examination Contact Letter.
Form 14726: Waiver of the Notice of Final Partnership Adjustment (FPA).
Form 15027: Partnership Summary of Approved Modifications.
Form 8988: Election for Alternative to Payment of the Imputed Underpayment (Section 6226 Push-Out).
Form 2848: Power of Attorney and Declaration of Representative.

12. Frequently Asked Questions (FAQs)

1. Why would a small partnership want to revoke its Section 6221(b) election out?

When an audit begins, handling the examination at the partnership level under the BBA is often much simpler and less expensive than forcing every partner to hire separate counsel and undergo individual audits. Revoking the opt-out allows the partnership to resolve all adjustments centrally through a single Partnership Representative.

2. What is the difference between Box A and Box B on Form 15288?

Box A is used to revoke an election out of the BBA under Section 6221(b) for tax years beginning after 2017. Box B is used to revoke an early opt-in election under Section 1101(g)(4) for transitional tax periods between late 2015 and early 2018.

3. Why must Form 8979 be attached to Form 15288?

When a partnership revokes its election out (Box A), it becomes subject to the BBA centralized audit regime. BBA rules mandate that every partnership must have a designated Partnership Representative to interface with the IRS. Form 8979 formally appoints that representative.

4. What is the exact deadline to file Form 15288?

If your partnership is under examination, Form 15288 must be received by the IRS within 30 calendar days from the date the partnership receives Letter 2205-D. Late requests are accepted only at the discretion of the IRS.

5. Who at the IRS approves Form 15288?

Under IRS Delegation Order 4-52, authority to accept and sign a partnership’s request to revoke an election is delegated to SB/SE Field Examination Group Managers and LB&I Team Managers.

6. Can an individual partner sign Form 15288?

Form 15288 must be signed by an authorized partner, member, or corporate officer acting on behalf of the partnership entity, or by an attorney holding an active Form 2848 Power of Attorney.

13. Conclusion: Key Takeaways

IRS Form 15288 is a critical procedural tool that allows small partnerships to transition from fragmented individual partner audits into the centralized BBA audit regime. By revoking a prior Section 6221(b) election out, a partnership can streamline its defense, appoint a single Partnership Representative, and utilize flexible BBA settlement and push-out mechanisms.

Because the form must be submitted within 30 days of receiving Letter 2205-D and strictly requires attaching Form 8979, managing partners and advisors should review their audit posture immediately upon receiving an exam notice and consult with an experienced partnership tax attorney or CPA when preparing Form 15288.

IRS Form 15288 Guide: Revoke Partnership Election Process