1. Introduction: What is Form 15307?

IRS Form 15307, officially titled Post-Filing Disclosure for Specified Large Business Taxpayers, is an administrative disclosure document published by the Internal Revenue Service (IRS). It is governed by the Large Business & International (LB&I) Division of the IRS under the procedural authority of Revenue Procedure 2022-39.

This form is not a standard annual tax return filed by everyday taxpayers or small businesses. Instead, Form 15307 is a specialized legal disclosure form used exclusively by large corporations and large partnerships that are under continuous or recurring IRS examinations. When an IRS audit begins, eligible large enterprises can submit Form 15307 to formally disclose errors, omissions, or adjustments on their previously filed tax returns, earning Qualified Amended Return (QAR) treatment that legally shields them from costly 20% accuracy-related penalties under Internal Revenue Code (IRC) Section 6662.

2. Purpose of the Form: Why Does Form 15307 Exist?

Under general federal tax rules (Treasury Regulation Section 1.6664-2(c)(3)), a taxpayer can only avoid accuracy-related penalties by filing a “Qualified Amended Return” before the IRS first contacts them regarding an audit. However, for America’s largest corporate and partnership enterprises—which are subject to near-constant, back-to-back IRS examinations under continuous audit programs—filing an amended return before the IRS initiates contact is practically impossible.

For nearly three decades, large corporations relied on informal written disclosure statements under Revenue Procedure 94-69 at the start of an audit. In late 2022, the IRS modernized and replaced that framework by issuing Revenue Procedure 2022-39 and creating Form 15307. The form solves several critical administrative and compliance challenges:

Standardizing Audit Disclosures: It replaces informal letters with a structured, uniform IRS form that standardizes how large taxpayers report post-filing adjustments.
Granting Penalty Protection: Disclosures properly submitted on Form 15307 are treated as Qualified Amended Returns, eliminating 20% civil penalties for negligence, disregard of rules, and substantial understatement of income tax.
Expanding Relief to Large Partnerships: While the old rules applied only to corporations, Form 15307 formally extends post-filing disclosure relief to large partnerships audited under the Bipartisan Budget Act (BBA) regime.
Eliminating Complex Amended Filings: It allows large businesses to disclose adjustments at the opening of an audit without having to prepare, assemble, and file voluminous formal amended returns (Forms 1120-X or amended Forms 1065).

3. Who Needs to File This Form?

Form 15307 is restricted to specific large business taxpayers that meet strict regulatory eligibility thresholds. You need to use Form 15307 if your enterprise meets all of the following criteria:

Your business was selected for an examination under the Large Corporate Compliance (LCC) program or the Large Partnership Compliance (LPC) program (or predecessor programs like the Coordinated Industry Case / CIC program).
Your business satisfies the four-out-of-five-year eligibility test: on the date the IRS first contacted you regarding the examination, at least four of your income tax returns for the five taxable years preceding the year under review were under examination.
You have identified errors, omissions, or adjustments (positive or negative) on your original return that you wish to disclose to the IRS examination team.
You want to secure statutory protection against Section 6662 accuracy-related penalties for the disclosed items.

4. Who Is Exempt / Not Required to File?

Because Form 15307 is tailored exclusively to large corporate and partnership audit programs, the vast majority of taxpayers cannot use it:

Small and Mid-Sized Businesses: Entities audited under standard examination procedures that do not meet the continuous 4-out-of-5-year audit test cannot use Form 15307. Non-qualifying businesses must use standard Qualified Amended Return procedures before being contacted by the IRS.
Individual Taxpayers: Wage earners, sole proprietors, and individual filers never use Form 15307.
Ineligible Tax Controversies: Form 15307 cannot be used to disclose or protect against penalties for:
- Reportable transactions and tax shelters under IRC Section 6662A.
- Transactions lacking economic substance under IRC Section 6662(b)(6).
- Civil fraud under IRC Section 6663.
Eligible Businesses with No Adjustments: Large taxpayers that have no errors or post-filing adjustments to report have no reason to submit the form.

5. When to File: Deadlines and Frequency

Form 15307 is an event-based disclosure document submitted once at the opening phase of an audit examination cycle. It carries an inflexible administrative deadline.

Under Section 4.02 of Revenue Procedure 2022-39, Form 15307 must be delivered to the IRS examination team no later than 30 calendar days from the date when the IRS provides written notice requesting the form (or another date agreed to in writing by the IRS team). This 30-day window expands upon the old 15-day rule under Rev. Proc. 94-69. Meeting this deadline is vital: late disclosures are not treated as Qualified Amended Returns, leaving the business fully exposed to 20% accuracy-related penalties on all audit adjustments.

6. Where and How to File

Form 15307 is an audit-specific document that cannot be submitted through consumer tax preparation software or attached to an annual e-filed return. Taxpayers must deliver it directly to their assigned examination team:

Direct Delivery to the Examination Team: Submit the completed Form 15307 directly to the LB&I Lead Case Manager or Revenue Agent conducting the audit.
Approved Transmission Methods: The form can be transmitted via secure encrypted email, secure digital transmission platforms, or mailed to the designated IRS address as per instructions provided in your audit opening correspondence.
Authorized Signatures: The form must be signed under penalties of perjury by an authorized corporate officer (such as the Vice President of Tax, Chief Financial Officer, or Treasurer) or the designated BBA Partnership Representative (PR).
Retain Delivery Records: Maintain an exact copy of the signed disclosure and formal transmission verification in your corporate audit defense archives.

7. Step-by-Step Instructions to Fill Form 15307

Form 15307 requires precise identification of the taxpayer, the specific tax return items being adjusted, and the factual basis of each disclosure. The table below outlines each section of the form.

Section	Item Name	Required Information & Standards
Part I	Taxpayer Information	Legal entity name, Employer Identification Number (EIN), tax year under audit, and program type (LCC or LPC).
Part II	Itemized Disclosures	Specific identification of each item, the dollar amount of adjustment, and nature of the controversy.
Part II Rules	Anti-Netting Standard	Each adjustment must be stated separately; no netting of positive and negative adjustments is permitted.
Part III	Informal Claims	Designation of whether negative adjustments are intended to serve as informal claims for refund.
Part IV	Perjury Execution	Original signature, corporate title, date, and phone number of the authorized corporate officer or PR.

Part I: Taxpayer Identification

Enter the complete legal name of the corporation or partnership exactly as reported on the original Form 1120 or Form 1065. Enter the entity’s nine-digit Employer Identification Number (EIN) and the specific tax year or years under examination. Indicate whether your audit is governed by the Large Corporate Compliance (LCC) program or the Large Partnership Compliance (LPC) program.

Part II: Itemized Disclosure of Adjustments

This is the core technical portion of Form 15307. Under Revenue Procedure 2022-39, a disclosure is considered adequate only if it reasonably apprises the IRS of:

The Identity of the Item: The exact line number, schedule, and account description on the original return.
The Dollar Amount: The precise numerical dollar amount of the adjustment. Recomputations of total tax are generally not required unless the item involves tax credits.
The Nature of the Controversy: A clear, concise explanation of the factual and legal background of the adjustment (e.g., timing differences, transfer pricing adjustments, or reclassified expenses).
No Netting of Adjustments: You must state each adjustment separately. For example, you cannot net a $10 million positive inventory adjustment against a $4 million negative depreciation adjustment; both must be listed as separate line items.

Part III: Designating Informal Refund Claims

If any of your disclosed items are negative adjustments (items that decrease taxable income or increase credits), indicate whether you want the disclosure to serve as an informal claim for refund or credit. To qualify as a valid informal claim, the description must state the grounds upon which the refund is based in sufficient detail to verify its accuracy.

Part IV: Signature Under Penalties of Perjury

An authorized corporate officer or BBA Partnership Representative must sign, date, and enter their corporate title. By signing, you swear under penalties of perjury that all factual descriptions, adjustment amounts, and supporting explanations are true, correct, and complete.

8. Required Documents and Information Needed Before Filling

Before preparing Form 15307, assemble the following accounting and tax records:

The formal written notice or Information Document Request (IDR) from the IRS examination team opening the 30-day disclosure window.
A copy of the originally filed Form 1120 or Form 1065, including all supporting schedules, statements, and attachments.
Documentation proving your audit history across the preceding five years to establish eligibility under the 4-out-of-5-year rule.
Tax provision workpapers, general ledger reconciliations, and trial balances supporting each disclosed adjustment.
A signed Form 2848 (Power of Attorney) if an outside law firm or accounting advisory team represents the business during the audit.

9. Common Mistakes to Avoid

Submitting a flawed Form 15307 can void your Qualified Amended Return status and trigger massive penalties. Avoid these frequent mistakes:

Netting Positive and Negative Adjustments: Revenue Procedure 2022-39 strictly prohibits netting. Disclosing a single net number instead of separate itemized adjustments invalidates the disclosure for penalty protection.
Providing Vague or Incomplete Descriptions: Writing generic notes like “miscellaneous accounting adjustments” without providing specific dollar amounts and legal context fails the statutory adequacy test.
Missing the 30-Day Window: Failing to submit Form 15307 within 30 calendar days of the IRS’s written request destroys your QAR protection unless you secured a formal written extension from the IRS beforehand.
Attempting to Disclose Ineligible Transactions: Using Form 15307 to disclose listed transactions, reportable tax shelters under Section 6662A, or transactions lacking economic substance will not shield you from penalties.
Filing Without Meeting Eligibility Rules: Submitting Form 15307 if your company does not meet the 4-out-of-5-year continuous audit test will result in an immediate rejection.

10. Penalties for Non-Filing or Errors

Form 15307 is an optional disclosure tool, so there are no direct fines for not filing it. However, the financial consequences of failing to submit a timely, accurate disclosure during a large business audit are staggering:

20% Accuracy-Related Penalties (IRC Section 6662): If the IRS uncovers tax understatements during the audit that were not disclosed on a Qualified Amended Return or Form 15307, the IRS will assess an automatic 20% penalty for negligence or substantial understatement of tax. On corporate adjustments totaling $50 million, this represents an immediate $10 million penalty.
Increased 40% Gross Valuation Misstatement Penalties: Disclosures that do not meet statutory adequacy standards fail to protect against heightened 40% penalties where valuation misstatements exist.
Compounding Daily Interest: All resulting tax deficiencies and assessed penalties accrue mandatory statutory interest from the original return due date until fully paid.
Perjury Prosecution: Knowingly submitting false adjustments or misleading statements on Form 15307 is a federal crime punishable under 26 U.S.C. Section 7206.

11. Related Forms or Schedules

Form 15307 operates within an interconnected system of corporate tax, partnership audit, and penalty disclosure forms:

Revenue Procedure 2022-39: The governing IRS administrative guidance establishing Form 15307 rules.
Form 1120: U.S. Corporation Income Tax Return.
Form 1065: U.S. Return of Partnership Income.
Form 8275: Disclosure Statement (used on original returns to disclose items contrary to IRS rulings).
Form 8275-R: Regulation Disclosure Statement (used to disclose positions contrary to Treasury regulations).
Form 8886: Reportable Transaction Disclosure Statement.
Form 2848: Power of Attorney and Declaration of Representative.

12. Frequently Asked Questions (FAQs)

1. How does Form 15307 differ from the old Revenue Procedure 94-69 rules?

Form 15307 standardizes the disclosure process using an official IRS form rather than informal letters, expands the submission deadline from 15 days to 30 days, and formally incorporates large partnerships under the BBA audit regime alongside large corporations.

2. What does “Qualified Amended Return” (QAR) status mean?

QAR status means the IRS treats your post-filing disclosure as if it were an amended return filed before the audit began. This legal status eliminates Section 6662 accuracy-related penalties (such as negligence or substantial understatement penalties) on all properly disclosed adjustments.

3. Can an eligible large partnership use Form 15307?

Yes. Revenue Procedure 2022-39 explicitly allows large partnerships audited under the Large Partnership Compliance (LPC) program that meet the 4-out-of-5-year rule to use Form 15307, executed by their designated Partnership Representative.

4. Can our company net our positive and negative adjustments together?

No. Treasury rules strictly forbid netting. Every adjustment must be broken out and stated separately with its own dollar figure and factual description.

5. Can we request an extension on the 30-day deadline?

Yes. The IRS examination team has the discretionary authority to grant an extension, but the agreement must be confirmed in writing before the original 30-day window expires.

6. Does submitting Form 15307 prevent the IRS from auditing other issues?

No. Form 15307 only protects disclosed items from accuracy-related penalties. It does not stop the IRS from examining those items or investigating any other aspect of the company’s tax return.

13. Conclusion: Key Takeaways

IRS Form 15307 is an indispensable risk-management tool for enterprise-level taxpayers under continuous IRS oversight. By utilizing Revenue Procedure 2022-39 to disclose adjustments within 30 days of an audit opening, corporations and large partnerships can secure Qualified Amended Return status and avoid millions of dollars in accuracy-related penalties.

Because the form requires precise, non-netted descriptions, strict adherence to the 30-day window, and verified eligibility under the four-out-of-five-year rule, corporate tax executives and general partners should work closely with experienced tax controversy counsel and CPA advisors when assembling Form 15307.

IRS Form 15307 Guide: Post-Filing Disclosure Audit Rules