8894 Request to Revoke Partnership Level Tax Treatment Electi

Form

8894

(Rev. September 2017)

Request to Revoke Partnership Level
Tax Treatment Election
▶ For
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Department of the Treasury
For tax year beginning
Internal Revenue Service
Name of partnership

Type
or
Print

OMB No. 1545-0123

partnership tax years beginning before January 1, 2018.
to www.irs.gov/Form8894 for the latest information.
, 20

, and ending

, 20
Employer identification number

Number, street, and room or suite no. If a P.O. box, see the instructions.
City or town, state or province, country, and ZIP or foreign postal code

Revocation—Available only for partnership tax years beginning before January 1, 2018
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 (prior to the amendment by the Bipartisan Budget Act of 2015
(BBA)) 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 tax 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.
Date

Signature

For Paperwork Reduction Act Notice, see instructions.

Cat. No. 37702J

Form 8894 (Rev. 9-2017)

Page 2

Form 8894 (Rev. 9-2017)

What’s New

Who Must Sign

The revocation made with this form is available only for
partnership tax years beginning before January 1, 2018 and for
tax years in which no election under Temporary Regulations
section 301.9100-22T is in effect.

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.

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

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) (prior to
amendment by BBA). 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.

Where To File
Form 8894 must be sent to the address below.
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.

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.

Paperwork Reduction Act Notice
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.
The time needed to complete and file this form will vary
depending on individual circumstances. The estimated burden
for business taxpayers filing this form is approved under OMB
control number 1545-0123 and is included in the estimates
shown in the instructions for their business income tax return.