Under the current regime a partnership audit adjustment is assessed against and collected from the partnership itself, in the year the audit concludes, at the highest applicable rate. That single design choice means the people who pay are the partners who happen to own the entity when the examination ends, not the partners who received the income being adjusted. This article explains how the imputed underpayment is computed, what modifications reduce it and who must supply the information, how the push-out election shifts the liability back to the reviewed-year partners and what it costs them, why the partnership representative holds authority that no partner can override, and which partnership agreement provisions have to be rewritten to allocate a burden the tax law deliberately misallocates. It closes with the small-partnership opt-out, the administrative adjustment request, and the diligence questions that belong in every partnership interest purchase.