- 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.