Form 8894 Request to Revoke Partnership Level Tax Treatment Electi

Form

8894

Request to Revoke Partnership Level
Tax Treatment Election

(Rev. September 2008)
Department of the Treasury
Internal Revenue Service

For tax year beginning

, 20

and ending

Partnership name, address, and ZIP code

OMB No. 1545-1955
, 20
Employer identification number

Revocation
We, the partners of the above named partnership, request permission to revoke the election to have the
provisions of subchapter C of chapter 63 of the Internal Revenue Code apply with respect to this partnership. We
understand that the revocation of this election will not become effective without IRS consent. All partners, who
were partners at any time during the tax year shown above, have signed this form.
Partners’ Signatures
All partners, who were partners at any time during the tax year shown above, must sign below.
Under penalties of perjury, I declare that I was a partner during the taxable year as stated above and my
signature confirms my agreement with the request for revocation. I have examined this consent statement, and to
the best of my knowledge and belief, it is true, correct, and complete.
Signature

For Paperwork Reduction Act Notice, see instructions.

Date

Cat. No. 37702J

Form

8894

(Rev. 9-2008)

Form 8894 (Rev. 9-2008)

Page

2

General Instructions

Paperwork Reduction Act Notice

Section references are to the Internal Revenue Code unless
otherwise noted.

We ask for the information on this form to carry out the
Internal Revenue laws of the United States. You are required
to give us the information. We need it to ensure that you are
complying with these laws and to allow us to figure and
collect the right amount of tax.
You are not required to provide the information requested
on a form that is subject to the Paperwork Reduction Act
unless the form displays a valid OMB control number. Books
or records relating to a form or its instructions must be
retained as long as their contents may become material in
the administration of any Internal Revenue law. Generally, tax
returns and return information are confidential, as
required by section 6103.

Purpose of Form
Form 8894 is used only by small partnerships revoking a
prior election to be governed by the unified audit and
litigation procedures as set forth in section 6231(a)(1)(B)(ii). A
“small partnership” is defined as any partnership having 10
or fewer partners each of whom is an individual (other than a
nonresident alien), a C corporation, or an estate of a
deceased partner. For this pupose, a husband and wife (and
their estates) are treated as one partner.
Note. If the partnership does not qualify as a small
partnership for the tax year shown (after a revocation of the
prior election), a revocation cannot be made and will not be
accepted.

The time needed to complete and file this form will vary
depending on individual circumstances. The estimated
average time is:

Where To File

Recordkeeping

Form 8894 must be sent to the address below.

Learning about the
law or the form

12 min.

Preparing and sending
the form to the IRS

13 min.

Department of the Treasury
Internal Revenue Service Center
Ogden, UT 84201
The form must be filed at the address listed above by the
due date (including extensions) of the partnership return for
the tax year shown. Notification will be sent as to the
acceptance or denial of the request for revocation.

Who Must Sign
Each partner who holds or held an interest in the partnership
during the tax year for which the revocation is filed must sign
the form. This includes all partners during the year, not just
those who were partners at the end of the tax year. This will
be deemed to have occurred if all partners listed on the
Schedules K-1 of the Form 1065 filed for the revocation year,
sign the request.
A husband and wife are generally considered as one
partner, and should both sign the election. One spouse may
sign for the other if acting under a power of attorney, which,
if not previously filed, must accompany this form. Corporate
partners should name the corporation, with the signature of
the appropriate corporate officer. Attach a continuation sheet
if more signature space is needed.

1 hr., 25 min.

If you have comments concerning the accuracy of these
time estimates or suggestions for making this form simpler,
we would be happy to hear from you. You can write to the
Internal Revenue Service, Tax Products Coordinating
Committee, SE:W:CAR:MP:T:T:SP, 1111 Constitution Ave.
NW, IR-6526, Washington, DC 20224. Do not send the form
to this address. Instead, see Where To File, above.