Identify the core shifts CPAR makes to partnership audit liability and administration, including the concept of the imputed underpayment.

Recognize scenarios where negative or positive adjustments—handled through push

out, modification, or AAR—affect partners’ tax obligations.

Distinguish among push

out statements, imputed

underpayment modifications, and AAR filings when choosing a compliance approach.

Select effective strategies for appointing and empowering a partnership representative to manage CPAR examinations and subsequent IRS interactions.