Just wait until you have to start "layering" these adjustments in prior years (i.e., multiple 8978 filings for the same tax year from different partnerships...issued year, after year, after year).  It's like stacking (filing) four amended returns on (for) the same tax year (all on one neat tax schedule).  Based on experience, I'm pretty sure the IRS has difficulty going back more than three years to check your math on those adjustments.  My guess.

I realize partners in later years don't want to pay the taxes of those that came before them, but without significant advances in technology (i.e., tax software; ours and/or the IRS'), the Centralize Partnership Audit regime under the BBA - and these forms - are no better solution than their predecessor.