This guide covers the centralized partnership audit regime from the return through judicial review. It begins with the entity-level determination rule and the imputed underpayment computation, including the netting limitations and the highest-rate assumption that make the default deliberately punitive. Modification chapters cover each available reduction — amended returns, tax-exempt partners, lower rates, character, and specific circumstances — together with the partner information gathering that all of them require. Separate chapters address the push-out election and its higher interest cost, tiered partnership mechanics, the partnership representative's unreviewable authority, and the opt-out election that most partnerships cannot make. Later chapters cover the consistency requirement, administrative adjustment requests, penalties determined at the partnership level, judicial review and the deposit requirement, and the partnership agreement provisions that reallocate a burden the tax law deliberately misassigns.