U.S. Individual Income Tax Return Forms

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Instructions for Form 8082

Department of the Treasury
Internal Revenue Service

(Rev. December 2024)

For use with Form 8082 (Rev. 10-2023)
Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)

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

General Instructions

Future Developments

Unless otherwise noted, references to sections 6221
through 6241 are to Internal Revenue Code (the Code)
sections as amended by BBA and are referred to as “BBA
proceedings.”

For the latest information about developments related to
Form 8082 and its instructions, such as legislation
enacted after they were published, go to IRS.gov/
Form8082.

What’s New

Instructions reordered. These instructions have been
reorganized to better distinguish between the use of Form
8082 as a notice of inconsistent treatment and as an AAR.

Reminders

Part I, line 1. Item C2 was added to Part I to indicate
whether a BBA AAR has adjustments that don't result in
an imputed underpayment.

Increased research credit reported by a BBA partnership. If an increased research credit is reported by a BBA
partnership, the BBA partnership doesn’t file an amended
return. Instead, the BBA partnership must file an AAR and
attach the following five items of information to that AAR.
1. Identify all the business components to which the
section 41 research credit relates for that tax year.
2. For each business component, identify all research
activities performed.
3. Name the individuals who performed each research
activity.
4. The information each individual sought to discover.
5. The total qualified employee wage expenses, total
qualified supply expenses, and total qualified contract
research expenses for the claim year. This may be done
using Form 6765, Credit for Increasing Research
Activities.

As part of the AAR process, the BBA partnership will
also submit Form 8985, Pass-Through
Statement—Transmittal/Partnership Adjustment Tracking
Report, and Form 8986, Partner’s Share of Adjustment(s)
to Partnership-Related Item(s), to the IRS and send Forms
8986 to its partners. The BBA partnership isn’t required to
provide the five items of information again on Forms 8985
and 8986. The BBA partners don’t need to attach the five
items of information to their original returns to which their
Forms 8986 are attached. For more information, see
Research Credit Claims (Section 41) on Amended
Returns Frequently Asked Questions at IRS.gov/
businesses/corporations/research-credit-claimssection-41-on-amended-returns-frequently-askedquestions.
Oct 28, 2024

Purpose of Form

Notice of inconsistent treatment. If you’re a partner in
a TEFRA or BBA partnership, an S corporation
shareholder, a beneficiary of an estate or trust, an owner
of a foreign trust, or a residual interest holder in a real
estate mortgage investment conduit (REMIC), you must
generally report items consistent with the way they were
reported by the partnership to the IRS on Schedule K-1,
Schedule K-3, Form 8986 (issued with a BBA AAR),
Schedule Q, and/or a foreign trust statement. However,
there may be reasons why you wish to report these items
differently. To do so, use Form 8082 and the instructions
under Inconsistent Treatment, later.

Note. A partner is bound to finally determined
adjustments on Form 8986 resulting from a BBA
partnership audit and may not use Form 8082 to report the
items differently.
Use Form 8082 to notify the IRS of any inconsistency
between your tax treatment of an item and the way the
pass-through entity treated and reported the same item on
its return. Also use the form to notify the IRS if you didn’t
receive Schedule K-1, Schedule Q, and/or a foreign trust
statement from the foreign trust by the due date for filing
your return (including extensions). Additionally, based on
the instructions for Schedule K-2, if the pass-through
entity was required to provide a Schedule K-3 but didn’t,
use Form 8082 to notify the IRS of this. However, for tax
years beginning before 2018, don’t file Form 8082 as a
partner in an electing large partnership (ELP). Instead,
you must report all partnership items in a manner
consistent with the way the partnership reported them on
Schedule K-1 (Form 1065-B), Partner's Share of Income
(Loss) From an Electing Large Partnership.

AAR under TEFRA. Form 8082 is also used if you’re
filing an AAR electronically to correct a previously e-filed
Form 1065, U.S. Return of Partnership Income. An AAR is:
• A request by the tax matters partner (TMP) to correct
items on the original partnership return;
• A request by a TEFRA partner (other than a partner in
an ELP), or residual interest holder, to correct
pass-through items on that person's income tax return; or
• A request by an ELP to correct items on the original
TEFRA partnership return.
Use the instructions under TEFRA AAR to complete Form
8082 for this purpose.

Cat. No. 62051N

Protective TEFRA AARs. Generally, a protective AAR is
a request for credit or refund based on current litigation or
expected changes in tax law or other legislation. The TMP
or partner with authority (PWA) files a protective AAR
when the right to a refund is contingent on future events
and may not be determinable until after the period for filing
an AAR has expired. Protective AARs are subject to AAR
statutes set forth in sections 6227, 6228, and 6229 (prior
to amendment by BBA).
If you're a TMP filing on behalf of the partnership, the
petition period described in section 6228 (prior to
amendment by BBA) can be extended by using Form
9248, Agreement to Extend the Time to File a Petition for
Adjustment by the Tax Matters Partner With Respect to
Partnership Items. A protective AAR must clearly state
that it is a protective AAR, alert the IRS to the essential
nature of the adjustment, and specify the line item to be
protected.

Form 8985, Pass-Through Statement—Transmittal/
Partnership Adjustment Tracking Report. Form 8985
is used to summarize and transmit Forms 8986 (by an
audited partnership, a partnership filing an AAR, or a
pass-through partner) in situations where the partners are
taking into account the adjustments. Form 8985 is also
used to report payments made and related calculations by
a pass-through partner, if applicable. See the instructions
for these forms for further information.

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AAR under BBA. Use Form 8082 if the partnership
representative (PR) (on behalf of the partnership) is filing
an AAR electronically to adjust a previously e-filed Form
1065. Also refer to the Instructions for Form 1065.
BBA created a new centralized partnership audit
regime generally effective for partnership tax years
beginning after 2017, replacing the consolidated audit
proceedings under sections 6221 through 6234 enacted
by TEFRA. All partnerships with tax years beginning after
2017 are subject to the centralized partnership audit
regime unless they make a valid election under section
6221(b). See section 6221(b) and the Instructions for
Form 1065 for information on which partnerships are
eligible to make this election.
For instructions on completing Form 8082 for this
purpose, see BBA AAR under Specific Instructions, later.

Definitions
Adjustment year. For BBA partnerships, the adjustment
year is the partnership tax year in which:
• An adjustment pursuant to the decision of a court in a
proceeding brought under section 6234, such decision
becomes final;
• An AAR is filed under section 6227; or
• A notice of final partnership adjustment is mailed under
section 6231 or, if the partnership waives the limitations
on assessments under section 6232(b), the waiver is
executed by the IRS.
BBA partnership. A partnership subject to the
centralized partnership audit regime is a BBA partnership.
All partnerships with tax years beginning after 2017 are
BBA partnerships unless they make a valid election out of
the centralized partnership audit regime. A partner in a
BBA partnership is referred to as a “BBA partner.” An AAR
filed by a BBA partnership is referred to as a “BBA AAR”
and must be filed by the PR.
Foreign trust statement. Any of the following annual
statements furnished by a foreign trust to its owners or
beneficiaries.
• Foreign Grantor Trust Owner Statement.
• Foreign Grantor Trust Beneficiary Statement.
• Foreign Nongrantor Trust Beneficiary Statement.
2

Form 8986, Partner’s Share of Adjustment(s) to Partnership-Related Item(s). Form 8986 was created for
partnerships to show each partner’s share of adjustments
to PRI as a result of a BBA audit or BBA AAR for situations
where the partners are taking into account the
adjustments.
Item. Any item of a partnership, S corporation, estate,
trust, or REMIC required to be taken into account for the
pass-through entity's tax year by the partners,
shareholders, beneficiaries, owners, or residual interest
holders of that pass-through entity.
Non-BBA partnership. Under BBA, certain partnerships
with 100 or fewer eligible partners for the tax year can
elect out of the centralized partnership audit regime. For
additional information, see the Instructions for Form 1065.
A partnership that elects out of the centralized partnership
audit regime is referred to as a “non-BBA partnership.”
Non-TEFRA partnership. A partnership with a tax year
beginning before 2018 that isn’t subject to TEFRA
proceedings and didn't elect into BBA for that tax year
beginning after November 2, 2015, and before January 1,
2018, is referred to as a “non-TEFRA partnership.”

Partner with authority (PWA). Each ELP must
designate a partner (or other person) as the PWA who
shall have the sole authority to act on behalf of the
partnership. See section 6255(b)(1) (prior to amendment
of BBA). If the partnership fails to designate a PWA, the
IRS can select any partner to serve as the partner with
such authority. The PWA has the authority to file an AAR
on behalf of the partnership. The PWA does this by filing
Form 8082.
Partnership-related items (PRIs). For BBA
partnerships, under section 6241(2)(B), a PRI is any item
or amount with respect to the partnership that is relevant
in determining the income tax liability of any person,
without regard to whether the item or amount appears on
the partnership's return. This includes an imputed
underpayment (IU) and an item or amount relating to any
transaction with, basis in, or liability of the partnership.
Partnership representative (PR). If the partnership is
subject to the centralized partnership audit regime,
section 6223 provides that the partnership must designate
a partner or other person with a substantial presence in
the United States as the PR who shall have the sole
authority to act on behalf of the partnership. If the
designated PR is an entity, the partnership must also
appoint a designated individual (DI) to act on behalf of the
entity PR. The partnership and all partners are bound by
the actions of the PR in dealings with the IRS under BBA.
Pass-through entity. A partnership (including an ELP), S
corporation, estate, trust, or REMIC.
Instructions for Form 8082 (Rev. Dec. 2024)

Reporting year. Reporting year is the partner’s tax
year(s) that includes the date the AAR partnership
furnished Forms 8986 to its partners.
Reviewed year. For BBA partnerships, the reviewed year
is the partnership’s tax year to which a partnership
adjustment relates.
Reviewed year pass-through partner. For purposes of
these instructions, under BBA, a reviewed year
pass-through partner is a pass-through entity that held an
interest in a BBA partnership at any time during the
reviewed year, which is the partnership tax year to which
the partnership adjustment relates. For example, if the
BBA AAR is filed to make an adjustment to income for the
2022 tax year, 2022 is the reviewed year.

amendment by BBA) are referred to as “TEFRA
proceedings”; partnerships that are subject to TEFRA
proceedings are referred to as “TEFRA partnerships.” An
AAR filed by the TMP of the TEFRA partnership is a
TEFRA AAR. Any partner in a TEFRA partnership may file
an AAR using Form 8082. TEFRA proceedings don't
apply to partnerships with tax years beginning after 2017.

Who Must File

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Schedule K-1. An annual schedule reporting the
partner's, shareholder's, or beneficiary's share of income,
deductions, credits, etc., from a partnership, S
corporation, estate, or domestic trust.

Schedule K-2. An extension of Form 1065, Schedule K,
used to report items of international tax relevance from the
operation of a partnership.
Schedule K-3. An extension of Schedule K-1 (Form
1065) generally used to report to partners their shares of
the items reported on Schedule K-2.

Schedule Q. A quarterly schedule reporting the residual
interest holder's share of taxable income or net loss from
the REMIC.

Tax matters partner (TMP). If the partnership is subject
to the TEFRA procedures, it can designate a partner as
the TMP for the tax year for which the return is filed. The
TMP is a general partner (in most cases, the TMP must
also be a U.S. person) designated by the partnership to
represent the partners in the consolidated audit and
litigation proceedings under sections 6221 through 6234
referred to as “TEFRA proceedings.” The designation is
made by completing the Designation of Tax Matters
Partner section on Form 1065 used for tax years
beginning before 2018.
Additionally, a REMIC may designate a tax matters
person in the same manner in which a partnership may
designate a TMP under Regulations section 301.6231(a)
(7)-1. When applying that section, treat all holders of a
residual interest in the REMIC as general partners. The
designation may be made by completing the Designation
of Tax Matters Person section on Form 1066, U.S. Real
Estate Mortgage Investment Conduit (REMIC) Income Tax
Return, for tax years beginning before 2018.
For a limited liability company (LLC), a member of the
LLC is treated as a partner and a member-manager is
treated as a general partner. A member-manager is any
owner of an interest in the LLC who, alone or together with
others, has continuing exclusive authority to make
management decisions necessary to conduct the
business for which the LLC was formed. If there are no
elected or designated member-managers, each owner is
treated as a member-manager. For details, see
Regulations section 301.6231(a)(7)-2.
TEFRA partnership. The consolidated audit
proceedings of sections 6221 through 6234 (prior to
Instructions for Form 8082 (Rev. Dec. 2024)

Notice of inconsistent treatment. Generally, file Form
8082 if any of the following apply.
• You believe an item wasn’t properly reported on the
Schedule K-1 or Schedule K-3 you received from the
partnership, or on a Form 8986 received from an AAR
partnership (but not an audited partnership), S
corporation, estate, or domestic trust; the Schedule Q you
received from the REMIC; or the foreign trust statement
you received from the foreign trust.
• You believe an item shown on your schedule or
statement is incorrect but it isn’t an item that otherwise
has to be reported on your tax return. For example, if you
believe that the percentage shown as your ownership of
capital at the end of the year wasn’t properly reported on
Schedule K-1, file Form 8082 to report this, even though
you aren’t otherwise required to report that percentage on
your tax return. If you discover this kind of inconsistency
after filing your original return, file an amended return to
report it. In the space provided on the amended return for
writing explanations, enter “See attached Form 8082.” If
the correction doesn’t affect your tax return, no amounts
need to be entered on the amended return if the Form
8082 item is the only reason for filing the amended return.
• The pass-through entity hasn’t filed a tax return or given
you a Schedule K-1, Schedule Q, or foreign trust
statement by the time you're required to file your tax return
(including extensions) and there are items you must
include on your return.
• If the pass-through entity didn’t provide you
Schedule K-3 and it was required to do so according to
the instructions for Schedule K-2.
If you don't notify the IRS that you're reporting an
item (Part I, line 1, box a) inconsistently, any
CAUTION deficiency (including any late filing or late payment
penalties applicable to the deficiency) that results from an
adjustment to make your amount or other treatment of the
item consistent with the amount or treatment of the item
on the pass-through entity's return may be assessed
immediately. An inconsistent item can exist on either your
original or amended return.

!

AAR under TEFRA. File Form 8082 if any of the
following apply.
• You’re requesting an administrative adjustment to
correct a previously filed partnership return for a TEFRA
partnership. S corporations, estates, and trusts can’t file
an AAR (see Who May Not File below for details).
• You’re a partner in a TEFRA partnership (other than a
partner in an ELP) or residual interest holder in a REMIC
requesting an administrative adjustment to correct
pass-through items on your income tax return.
AAR under BBA. File Form 8082 if you're the PR or DI
requesting an administrative adjustment to correct a
3

previously filed partnership return on behalf of the BBA
partnership.
When a partnership’s federal return is changed for

TIP any reason, it may affect its state return. For more

information, contact the state tax agency with
which the state return is filed.

Who May Not File

• If you’re a beneficiary of an estate or domestic trust, or a
beneficiary or an owner of a foreign trust, except as a
notice of inconsistent treatment when the beneficiary's or
owner's return isn’t consistent with the return of the estate
or trust. Form 8082 can’t be filed by a beneficiary or owner
to request an administrative adjustment to their tax return
to correct estate or trust items. Instead, the beneficiary or
owner must file an amended income tax return.
• If you're a residual interest holder and your REMIC had
no more than one residual interest holder at any one time
during the tax year.
• If you're a residual interest holder in a REMIC that at
any time during the tax year beginning prior to January 1,
2018, had more than one residual interest holder; and
° Each residual interest holder was either an individual
(other than a nonresident alien), an estate, or a C
corporation; and
° The REMIC didn't have an election in effect under
section 6231(a)(1)(B)(ii) (prior to amendment by BBA)
for the tax year to have the TEFRA consolidated audit
rules apply; and
° The REMIC didn't have an election in effect pursuant
to section 1101(g)(4) for the tax year to early elect into
BBA.
If
• you're a residual interest holder in a REMIC with a tax
year beginning after December 31, 2017, that has an
election out of BBA in effect pursuant to section 6221(b).
• If you’re a partner in an ELP for tax years before 2018.
Partners must report all partnership items consistently
with their treatment on the partnership return as shown on
Schedule K-1 (Form 1065-B). Only the partnership may
file an AAR.

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Don't use Form 8082 to file a notice of inconsistent
treatment or an AAR if any of the following apply.
• If you’re a REMIC and want to correct items on the
original REMIC return. Instead, file Form 1065-X.
• For any amount of loss, deduction, or credit from
Schedule K-1, Schedule K-3, Schedule Q, Form 8986, or
the foreign trust statement that you don't report on your
return because the amount is otherwise limited by law
(such as a loss limited by the at-risk or passive activity
rules).
• If you’re a partner, and all five of the following elements
apply.
° The tax year of the partnership began prior to
January 1, 2018.
° The partnership didn’t make an early election into
BBA.
° Your partnership had no more than 10 partners at
any one time during the tax year. A married couple
(and their estates) are treated as one partner.
° Each partner was either an individual (other than a
nonresident alien) or an estate of a deceased partner,
or a C corporation.
° The partnership didn’t have an election in effect
under section 6231(a)(1)(B)(ii) (prior to amendment by
BBA) for the tax year to have the TEFRA consolidated
audit rules apply.
• If you're a partner in a partnership with a tax year
beginning after December 31, 2017, that has an election
out of BBA in effect pursuant to section 6221(b).
• If you’re a BBA partnership, you may not file an AAR
solely for the purpose of changing the PR. See the
Instructions for Form 8979, Partnership Representative
Revocation, Designation, and Resignation, for more
information.
• You may not file a BBA AAR after the prescribed time to
do so (see How and When To File, later).
• If you’re a BBA partnership that has received a notice of
administrative proceeding, you may not file an AAR.
• If you’re a partner and the BBA partnership in which
you’re an investor has received a notice of administrative
proceeding, a Form 8082 with respect to inconsistent
treatment of partnership items from that BBA partnership
can’t be filed.
• A partner may not file an AAR on behalf of the BBA
partnership in which it’s a partner unless doing so is in its
capacity as the PR for that partnership.
• If you’re a shareholder in an S corporation, except as a
notice of inconsistent treatment when the shareholder's
return isn’t consistent with the return of the S corporation.
Form 8082 can’t be filed by a shareholder to request an
administrative adjustment to their tax return to correct S
corporation items. Instead, the shareholder must file an
amended income tax return.
4

Interest and Penalties

If you disregard the requirements for filing Form 8082, you
may be subject to the accuracy-related penalty under
section 6662 or the fraud penalty under section 6663.
Either penalty is in addition to any tax that results from a
computational adjustment to make your amount or
treatment of the item consistent with the amount or
treatment of the item on the pass-through entity's return.
Interest. Generally, interest is charged on taxes not paid
by the due date, even if an extension of time to file is
granted. Interest is also charged on penalties imposed for
negligence, fraud, substantial valuation misstatements,
substantial understatements of tax, and reportable
transaction understatements. The interest is charged from
the due date (including extensions) to the date of
payment. The interest charge is figured at a rate
determined under section 6621.
Late payment penalty. The penalty for not paying the
tax when due is usually 1/2 of 1% of the unpaid tax for
each month or part of a month that the tax remains
unpaid. The penalty can’t exceed 25% of the unpaid tax.
Other penalties. Penalties can also be imposed for
negligence, substantial understatements of tax, reportable
transaction understatements, and fraud. See sections
6662, 6662A, and 6663.
Interest and penalties applicable to IU. Except when
the partnership elects to have its partners take into
Instructions for Form 8082 (Rev. Dec. 2024)

account the adjustments, BBA partnership interest and
penalties are the following.
• The interest figured for an IU is the interest that would
be determined under chapter 67 for the period beginning
on the day after the return due date for the reviewed year
and ending on the return due date for the adjustment year
as defined under section 6225(d)(2) or, if earlier, the date
the IU is paid.
• Any penalty, addition to tax, or additional amount that is
determined at the partnership level is applied as if that
BBA partnership had been an individual subject to tax
under chapter 1 for the reviewed year and the IU were an
actual underpayment (or understatement) for that year for
purposes of part II of subchapter A of chapter 68.

• The date on which the pass-through entity return for
that year is filed, or
• The last day for filing the pass-through entity return
for that year (excluding extensions);
2. In the case of a TEFRA partnership or REMIC,
before a notice of final partnership administrative
adjustment for that year is mailed to the TMP or tax
matters person; or, in the case of an ELP, before the
mailing to the partnership of a notice of partnership
administrative adjustment for that year; or
3. In the case of a BBA partnership, before a notice of
an administrative proceeding for the tax year is mailed
under section 6231.

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Election to apply the alternative to payment of the IU.
If the partners must take into account the adjustments
because the BBA partnership filed an AAR and there are
adjustments that don't result in an IU or if a BBA
partnership elects the alternative to payment of the IU
under sections 6227(b)(2) and 6226(c), interest shall be
determined:
• At the partner level;
• From the due date of the return for the tax year to which
the increase is attributable, determined by taking into
account any increases attributable to a change in tax
attributes for a tax year under section 6226(b)(2) until the
date of payment; and
• At the section 6621(a)(2) underpayment rate.

How Many Forms To Complete

You must complete and file a separate form for each
pass-through entity for which you’re reporting an
inconsistent or AAR item. If you’re reporting more than
four inconsistent or AAR monetary items from one
pass-through entity, use additional Forms 8082 because
Part II only provides four lines (8 through 11). You don’t
need to complete lines 8 through 11 if not reporting a
change to the amount or treatment of a monetary item;
however, you must include an explanation of the
change(s) in Part III.

How and When To File

Don’t file Form 8082 by itself.
• If you file Form 8082 as a notice of inconsistent
treatment, complete a single copy of the form, attach it to
your tax return, and file it when you file your original return.
• If a TMP, PR, or ELP files Form 8082 as an AAR on
behalf of the partnership, the TMP, PR, or ELP must
complete the form, attach it to the partnership's amended
tax return, and file it with the service center where the
original return was filed.
• If a partner in a TEFRA partnership or residual interest
holder files Form 8082 as an AAR, it must be filed in
duplicate. The original copy is filed with the partner's or
residual interest holder's amended income tax return, and
the other copy is filed with the service center where the
pass-through entity return is filed. See Notice of
inconsistent treatment filed with return under Inconsistent
Treatment—Part II, later.

A partnership return or a REMIC return is generally due
by the 15th day of the 3rd month following the close of the
partnership's or REMIC's tax year. The tax year of a
REMIC always ends on December 31.

Special rules apply if the period of limitations has been
extended by agreement and in the case of a TEFRA AAR
that relates to the deductibility of bad debts or worthless
securities. See sections 6227 (prior to amendment by
BBA) and 6251 for details.

What To Attach

If applicable, attach the following items to Form 8082.
• If the corrected amount involves an item that must be
supported with a schedule, statement, or form, attach the
appropriate schedule, statement, or form. Include the
entity's name and employer identification number (EIN) on
any attachments. See the instructions for Forms 1065,
1065-B, or 1066 (as applicable) for a list of forms that may
be required.
Note. If the attachments needed to support the corrected
amount include copies of forms or schedules from
previously filed tax returns, enter at the top of each
previously filed form or schedule, “Copy Only—Don't
Process.”
• A BBA partnership must attach a schedule to Form
8082 that supports the position(s) reported. If the
partnership doesn’t make an election under section
6227(b)(2) to have the adjustments taken into account by
the reviewed year partners and would like to modify per
section 6227(b)(1), it must attach a Form 8980,
Partnership Request for Modification of Imputed
Underpayments Under IRC Section 6225(c), that supports
any modifications made to the IU as described in sections
6225(b) and 6225(c) and as applied to a BBA AAR under
section 6227(b)(1). See Modifications to an Imputed
Underpayment Included in an Administrative Adjustment
Request in Pub. 5346, Instructions for Form 8980.
• Attach Forms 8985 and 8986, as applicable. Form 8986
is used by BBA partnerships to furnish and transmit each
partner’s share of adjustments to PRIs. See the
instructions for Forms 8985 and 8986 for more
information.
• If the AAR is a request for an electronically deposited
refund of $1 million or more, attach Form 8302, Electronic
Deposit of Tax Refund of $1 Million or More.

Generally, a pass-through entity may file an AAR to
change items on its return:
1. Within 3 years after the later of:
Instructions for Form 8082 (Rev. Dec. 2024)

5

Judicial Review of an AAR (for
Returns Subject to the TEFRA
Procedures or ELPs)

If the IRS fails to act on an AAR, the TMP or PWA may file
a petition for judicial review with the U.S. Tax Court, U.S.
Court of Federal Claims, or U.S. District Court. The TMP
or PWA must file the petition before the date that is 2
years after the date the TMP or PWA filed the AAR, but
not until after the date that is 6 months from the date of
such filing. The 2-year period may be extended if the IRS
and the TMP or PWA agree in writing. For more details,
see sections 6228 (prior to amendment by BBA) and
6252.

AAR With Election Into the
Centralized Partnership Audit Regime
Under BBA

Certain partnerships may elect to have the new
centralized partnership audit regime apply to a return filed
for an eligible tax year when filing an AAR under section
6227. An eligible tax year is any tax period beginning after
November 2, 2015, and before January 1, 2018. Only
partnerships can file an AAR under section 6227. A
partnership may not make this election where:
• An AAR has been filed on behalf of the partnership
under section 6227(c) (prior to amendment by BBA), or
• An amended return for the partnership has been filed.
See Regulations section 301.9100-22(c)(4).

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Special Rules for ELPs for Tax Years
Beginning Before 2018

An ELP may file an AAR to adjust partnership items.
However, a partner may not file an AAR. Generally, the
ELP has two choices for handling the adjustment.
1. It can combine the adjustment with the same
partnership item for the year in which the IRS allows the
adjustment and pass it through to the current partners for
that year. However, if the adjustment involves a reduction
in a credit that exceeds the amount of that credit for the
partnership tax year in which the adjustment is allowed,
the partnership must pay tax in an amount equal to that
excess amount.
2. It may elect to not pass the adjustment through to
current partners by paying tax on any IU that results from
the adjustment, as explained in section 6242(b)(4), prior
to amendment by BBA.

In either case, the partnership is liable for any interest
and penalties on the IU that result from the adjustment.
See section 6242(b) for details. Interest is figured on the
IU for the period beginning on the day after the due date
(excluding extensions) of the partnership return for the
adjusted year and ending on the due date (excluding
extensions) of the partnership return for the tax year the
adjustment takes effect, or, if earlier, the date the
partnership paid the tax due under (2) above. The
adjusted year is the partnership tax year in which the item
being adjusted arose.
How to file. Attach Form 8082 to an amended Form
1065-B for the adjusted year. Enter in the top margin of
the amended return, “See attached Form 8082 for AAR
per IRC section 6251.” Be sure to check box G(4) on
page 1 of the amended return. Identify in Part II of Form
8082 the amount and treatment of any item the
partnership is changing from the way it was reported on
the original return. If the partnership elects to pay the tax,
enter it on line 26 of page 1 of the amended Form 1065-B.
Don't enter any other amounts on the amended Form
1065-B. Attach a computation of the tax to Form 8082.
The IRS will bill the partnership for any interest and
penalties it owes.
If the income, deductions, credits, or other information
provided to any partner on Schedule K-1 is incorrect, file
an amended Schedule K-1 (Form 1065-B) for that
partner(s) with Form 8082. Also give the partner(s) a copy.
6

An AAR filed for an eligible tax year before January 1,
2018, will be treated as an AAR filed on behalf of a
TEFRA partnership or as an amended return filed on
behalf of a non-TEFRA partnership, as applicable. An
AAR filed after January 1, 2018, for an eligible tax year
without a statement attached to the AAR on which the
partnership makes the election into the centralized
partnership audit regime will be treated as an AAR filed on
behalf of a TEFRA partnership or as an amended return
filed on behalf of a non-TEFRA partnership, as applicable.
Once made, an election may only be revoked with the
consent of the IRS.
Note. An AAR filed for a 2018 short tax period return by a
partnership that is subject to the centralized partnership
audit regime must meet the requirements under section
6227.

Making the election. To make the election, the
partnership must enter across the top of Form 1065 used
to file the AAR, “Election under Section 1101(g)(4)” and
attach a statement to the AAR. For the statement
requirement, the partnership can use Form 7036, Election
Under Section 1101(g)(4) of the Bipartisan Budget Act of
2015. If Form 7036 isn’t used, the partnership may
prepare its own statement with the following information.
• The partnership's name and taxpayer identification
number (TIN), and the partnership tax year for which the
election is being made.
• The name, TIN, address, and daytime telephone
number of the individual who signs the statement.
• Language indicating that the partnership is electing
application of section 1101(c) of BBA for the partnership
return for the eligible tax year.
• The information required to properly designate the PR
as defined by section 6223, which must include the name,
TIN, address, and daytime telephone number of the PR.
• The following representations must be made on the
statement of election.
° The partnership isn’t insolvent and doesn’t
reasonably anticipate becoming insolvent before
resolution of any adjustment with respect to the
partnership tax year for which the election is being
made.
° The partnership hasn’t voluntarily filed, and doesn’t
reasonably anticipate filing, a petition for relief under
title 11 of the United States Code.
Instructions for Form 8082 (Rev. Dec. 2024)

° The partnership isn’t subject to, and doesn’t
reasonably anticipate becoming subject to, an
involuntary petition for relief under title 11 of the United
States Code.
° The partnership has sufficient assets, and
reasonably anticipates having sufficient assets, to pay
a potential IU with respect to the partnership tax year
that may be determined under subchapter C of
chapter 63 of the Code, as amended by BBA.
• A representation, signed under penalties of perjury, that
the individual signing the statement is duly authorized to
make the election described in Regulations section
301.9100-22 and that, to the best of the individual's
knowledge and belief, all of the information contained in
the statement is true, correct, and complete.
• The statement must be signed and dated by the TMP,
as defined under section 6231(a)(7) (prior to amendment
by BBA), and the applicable regulations, or an individual
who has the authority to sign the partnership return for the
tax year. The fact that an individual dates and signs the
statement making the election shall be prima facie
evidence that the individual is authorized to make the
election on behalf of the partnership.

section 1101(g)(4) of BBA, the partnership uses Form
1065 and Form 8082 including the statement “Election
Under Section 1101(g)(4).”

Specific Instructions
Specific instructions for most of the lines have been
provided. Lines that aren’t explained are self-explanatory.

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Imputed underpayment (IU). Partnerships filing an AAR
with an election into the centralized partnership audit
regime under BBA will need to determine if any
partnership adjustment as defined by section 6241(2)
results in an IU as described in section 6225(b). See
section 6225(c), excluding paragraphs (2), (7), and (9), for
guidance regarding the modification rules that may apply
to an IU.
If modification is applied to an IU, the AAR must include
detailed documentation to support all modifications made
to the IU.
Unless the partnership elects under section 6227(b)(2)
to have the partners take the adjustments into account, if
the partnership adjustment results in an IU, the
partnership must report and pay the IU and any interest
and penalty associated with the IU at the time the AAR is
submitted. See Interest and penalties applicable to IU,
earlier.
Unless the calculation of the IU contains a permitted
rate modification per section 6225(c)(4), the IU will be
figured using the highest rate in effect under section 1 or
11 for the tax year to which the adjustment relates. Enter
“BBA Imputed Underpayment” in the bottom margin of
page 1 (Form 1065) and include the IU and any interest or
penalties related to the IU.
If the partnership elects under section 6227(b)(2) to
have the partners take the adjustments into account or
there are adjustments that don't result in an IU, the
partnership is required to furnish statements to each
partner of the partnership for the reviewed year, and file
statements with the AAR. See the instructions for Forms
8985 and 8986 for more information.
Note. BBA partnerships must file an AAR instead of an
amended return and won’t attach amended Schedules
K-1 to the AAR. Go to IRS.gov/BBAAAR for instructions
for electronically submitting a BBA AAR.
Filing an AAR electronically. If the AAR is filed
electronically, and an election is being made under
Instructions for Form 8082 (Rev. Dec. 2024)

Note. If the pass-through entity didn’t file a return or give
you a Schedule K-1, Schedule K-3 (and according to the
instructions for Schedule K-2, the pass-through entity was
required to provide one to you), Schedule Q, and/or
foreign trust statement by the time you're required to file
your return, complete Parts I and II to the best of your
knowledge.

Inconsistent Treatment

Name and Identifying Number

Enter the legal name of the entity and identifying number
on the appropriate lines.

Part I—General Information
Line 1

Check box (a) if you believe an item wasn't properly
reported on Schedule K-1, Schedule K-3, Schedule Q,
Form 8986 (only issued with respect to an AAR), and/or
foreign trust statement you received, or if you haven't
received a Schedule K-1, Schedule K-3 (that the
pass-through entity was required to provide according to
the instructions for Schedule K-2), Schedule Q, or foreign
trust statement by the time you're required to file your tax
return (including extensions). Go to line 2.

Lines 2 Through 6
Generally, the information for these lines can be found on
Schedule K-1, Form 8986, Schedule Q, or the foreign trust
statement.
Line 6. Tax year of pass-through entity. If you're a
partner filing a notice of inconsistent treatment from a
Form 8986 received as a result of a BBA partnership AAR,
use the date contained in Form 8986, Part II, box D.

Part II—Inconsistent or Administrative
Adjustment Request (AAR) Items
Partner filing a notice of inconsistent treatment for a
Schedule K-1 or Schedule K-3 received from a BBA
partnership. When a partner receives a Schedule K-1 or
Schedule K-3 from a BBA partnership, it must generally
file consistently with that Schedule K-1 or Schedule K-3.
However, a partner may file inconsistently if it provides
valid notice to the IRS of inconsistent treatment.
Notice of inconsistent treatment filed with return.
If a pass-through partner doesn’t receive a Schedule K-1
or Schedule K-3 (and the pass-through entity was
required to provide one according to the instructions for
Schedule K-2) from a BBA partnership or does receive a
Schedule K-1 or Schedule K-3 but disagrees with some or
all of the reported treatment or amounts, it may file a
7

notice of inconsistent treatment with its return (original or
amended/AAR). To do so, as a pass-through partner,
you’ll include Form 8082 with your return (for example,
Form 1065, Form 1120-S), prepare your return using the
treatment or amounts you determine are correct, and do
the following.
1. On Form 8082, check box (a) under Part I, line 1
(and box (b), if applicable).
2. See Lines 8 Through 11, later, for how to complete
Part II, columns (a) through (e).
3. File Form 8082 along with the applicable return and
attach any other supporting documents required.

Lines 8 Through 11
Note. Lines 8 through 11 are only required if reporting a
change to the amount or treatment of a monetary number.
Column (a).
Inconsistent treatment. If you received a
Schedule K-1, Schedule K-3, Schedule Q, Form 8986 (as
a result of a BBA AAR, and not as a result of an audit),
and/or foreign trust statement, enter the line number and
description shown on the form. Otherwise, enter a
complete description of the item.
If you didn’t receive a Schedule K-1, Schedule K-3,
Schedule Q, and/or foreign trust statement but are still
reporting estimated amounts on your original filing, enter a
completed description of the item and where you're
reporting the estimated amount on your original return. For
example, if you're a BBA partnership-partner providing
notice of inconsistent treatment for a Form 8986 received
(as a result of a BBA AAR, and not as a result of an audit),
enter the information from the first three columns of Form
8986, Part V, that you're treating inconsistently.

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Pass-through partner filing a notice of inconsistent
treatment for a Form 8986 received from a BBA partnership filing an AAR. When a pass-through partner
receives Form 8986 as a result of an AAR filed by a BBA
partnership in which it’s an indirect or direct investor, that
pass-through partner will (prior to the date contained in
Form 8986, Part II, box F) take one of the following
actions.
• Push out all the adjustments that are on the Form 8986
to its partners, shareholders, or beneficiaries. The
pass-through partner will prepare and file with the IRS
Form 8985 and Forms 8986.
• For the adjustments resulting in an IU, pay the IU on
those adjustments and prepare and issue to its partners,
shareholders, or beneficiaries Forms 8986 for those
adjustments that don't result in an IU. The pass-through
partner will prepare and file with the IRS Form 8985 and
Forms 8986.
Note. Pass-through partners aren’t permitted to apply
modifications to the IU.
• When Form 8986 only contains adjustments that don't
result in an IU, prepare and issue to its partners,
shareholders, or beneficiaries Forms 8986 for those
adjustments. However, a pass-through partner may file
inconsistently if it provides valid notice to the IRS of
inconsistent treatment.

Note. Any partner (including a pass-through partner) that
receives Form 8986, as a result of an audit, isn't permitted
to treat items on that Form 8986 inconsistently and must
report consistently with the information provided on Form
8986.
Other than pass-through partner filing a notice of inconsistent treatment from a BBA partnership. If
you're a partner (other than a pass-through partner) filing
inconsistently from a BBA partnership (that is,
inconsistently from a Schedule K-1, Schedule K-3, and/or
Form 8986 you received as a result of a BBA partnership
filling an AAR, and not as a result of an audit), complete
Form 8082 and attach it to your original or amended
return. If filing inconsistently from a Form 8986 (received
as a result of a BBA partnership filing an AAR and not as a
result of an audit), attach Form 8082 to your reporting year
return that corresponds to the Form 8986 received. Attach
a copy of the Form 8986 received from which you’re filing
inconsistently. See Reporting year, earlier. See Lines 8
Through 11 below for how to complete Part II, columns (a)
through (e).
8

Column (b).
Inconsistent treatment. If you believe that the amount
of any item shown on Schedule K-1, Schedule K-3,
Schedule Q, Form 8986 (as a result of a BBA AAR, and
not as a result of an audit), and/or a foreign trust statement
wasn’t properly reported, check the box under “Amount of
item.”
If you believe that treatment of any item (other than the
amount of the item) wasn’t properly reported (such as a
long-term capital loss that a partner thinks should be an
ordinary loss), check the box under “Treatment of item.”
Check both parts of column (b) if either (1) or (2) below
applies.
1. You believe that both the amount and another
treatment (besides the amount) of the item shown on
Schedule K-1, Schedule K-3, Schedule Q, Form 8986 (as
a result of a BBA AAR, and not as a result of an audit),
and/or a foreign trust statement weren’t properly reported,
or you believe an item was omitted from the form.
2. The pass-through entity didn’t file a return or give
you a Schedule K-1, Schedule K-3 (and the pass-through
entity was required to provide one to you according to the
instructions for Schedule K-2), Schedule Q, and/or foreign
trust statement.
Note. If you check only “Treatment of item,” you don't
need to complete columns (d) and (e).
Column (c).
Inconsistent treatment. If you attach Form 8082 to
your return, to make a notice of inconsistent treatment,
enter the amount as shown on the Schedule K-1,
Schedule K-3, Schedule Q, and/or foreign trust statement
you received.
If the pass-through entity didn’t file a return, or if you
didn’t receive a schedule or statement, or if you're
reporting items that you believe were omitted, enter zero
in column (c).
If you receive Form 8986 as a result of a BBA AAR (and
not as a result of an audit), do the following to make a
notice of inconsistent treatment.
Instructions for Form 8082 (Rev. Dec. 2024)

• Pass-through partner preparing Form 8985, attach
Form 8082 to the Form 8985 you file.
• Other than pass-through partner, attach Form 8082 to
the copy of the return (or amended return) you file.
If treating any liabilities or capital items reported to you
in Form 8986, Part IV, inconsistently, enter the item
amount from Form 8986, Part IV, “Corrected” column, in
Form 8082, Part II, column (c).
If treating an item of income, gain, loss, deduction, or
credits, or other items reported to you in Form 8986, Part
V, inconsistently, enter the sum of Form 8986, Part V,
columns (d) and (h), in Form 8082, Part II, column (c).
If treating any items reported to you in Form 8986, Part
VI, inconsistently, enter that item amount from Form 8986
in Form 8082, Part II, column (c).

Subject to the particular filing rules, an AAR can be filed
by partnerships subject to TEFRA proceedings (TEFRA
AAR), and ELPs. An AAR can also be filed by the
following partners.
• Partners of a TEFRA partnership.
• Residual interest holders (of REMICs subject to
TEFRA).

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Column (d). Enter the amount you’re reporting as the
correct amount in column (d).

Column (e). Enter the net increase or decrease for each
line being changed in column (e). Enter as a positive the
amount by which column (d) exceeds column (c) or enter
as a negative the amount by which column (c) exceeds
column (d). Use parentheses around all amounts that are
negative. Explain the reason for the change (increase or
decrease) in Part III.

Part III—Explanations

Explain in detail the reasons you're reporting an
inconsistent or corrected amount or item as follows.
• If you believe that the amount or other type of treatment
of any item shown on Schedule K-1, Schedule K-3,
Schedule Q, Form 8986 (as a result of a BBA AAR, and
not as a result of an audit), and/or a foreign trust statement
wasn’t properly reported, state how you think the item
should be treated and why.
• If the pass-through entity hasn’t filed a tax return by the
time you're required to file your tax return, enter as the
explanation, “Partnership (S corporation, Estate, Trust, or
REMIC) return not filed.”
• If the pass-through entity didn’t give you a
Schedule K-1, Schedule K-3 (and the pass-through entity
was required to provide one to you according to the
instructions for Schedule K-2), Schedule Q, and/or foreign
trust statement by the time you're required to file your tax
return, enter as the explanation, “Schedule K-1
(Schedule K-3, Schedule Q, and/or foreign trust
statement) not received.”

TEFRA AAR
Name and Identifying Number

Enter the legal name of the entity and identifying number
on the appropriate lines.

Part I—General Information
Line 1
Check box (b) if you're filing an AAR on which you're
requesting a change in the amount or treatment of any
item from the way you reported it on your return as
originally filed or as you later amended it.

Instructions for Form 8082 (Rev. Dec. 2024)

For Partnership Tax Years Beginning Before
January 1, 2018 (Unless Electing Into BBA)

TEFRA AAR. The consolidated audit proceedings of
sections 6221 through 6234 (prior to amendment by BBA)
are referred to as “TEFRA proceedings.” Partnerships that
are subject to TEFRA proceedings are referred to as
“TEFRA partnerships.” An AAR filed by the TMP of the
TEFRA partnership is a TEFRA AAR. Form 8082 is also
used by any partner in a TEFRA partnership filing an AAR.
TEFRA proceedings won’t apply to partnerships with tax
years beginning after 2017. A partnership with a tax year
beginning before 2018 that isn’t subject to TEFRA
proceedings is referred to as a “non-TEFRA partnership.”
TEFRA partnerships requesting substituted return
treatment. A substituted return requests that the
treatment of an item shown on the AAR be substituted for
the treatment of the item on the pass-through entity's
return. If the IRS allows substituted return treatment, the
changes shown on the amended return will be treated as
corrections of mathematical or clerical errors, and the IRS
may assess any resulting tax to the partners or residual
interest holders without a deficiency or entity-level
proceeding, or partners or residual interest holders may
file an amended return requesting a refund. See section
6227(c)(1) (prior to amendment by BBA).
If you’re a TMP filing a TEFRA AAR on behalf of the
partnership and requesting substituted return treatment,
attach a statement to Form 8082 indicating that you're
requesting substituted return treatment.
If the request isn’t treated as a substituted return, the
partners or residual interest holders may file amended
returns requesting a refund. The IRS may conduct an
examination of the pass-through entity’s return, or take no
action on the request. When a request isn’t treated as a
substituted return, the IRS can’t assess tax without a
deficiency or entity-level proceeding. See section 6227(c)
(2) (prior to amendment by BBA).
In either case, if you’re a TMP filing an AAR
electronically, file an amended Form 1065, but don't enter
any amounts on the form itself. Attach Form 8082 and
identify the amount and treatment of any item you're
changing from the way it was reported on the original
return. The TMP must sign the amended return.
Attach amended Schedules K-1 showing the corrected
amounts for each partner.
ELP AAR. The ELP procedures were repealed for tax
years beginning after 2017. However, ELPs filing an AAR
after 2017 for a tax year that began before 2018 will use
Form 8082.

9

Part II—Inconsistent or Administrative
Adjustment Request (AAR) Items
TEFRA partnerships and ELPs filing AARs. If a
TEFRA partnership/ELP is filing an AAR to change items
that were reported on its original return, do the following.
1. Determine the required changes to be made.
2. Complete Form 8082 to identify the changes being
made.
a. On Form 8082, check box (b) under Part I, line 1.
b. See Lines 8 Through 11 below for how to complete
Part II, columns (a) through (e).
3. Complete Form 1065.
a. File an amended Form 1065 (checking box G5).
b. The TMP must sign the amended return.
c. Attach amended Schedules K-1 showing the
corrected amounts for each partner.
4. File Form 8082 along with Form 1065 and attach
any other supporting documents required.
5. Give a copy of the amended Schedules K-1 to the
applicable partners.

Column (b).
AAR. Check the box under “Amount of item” if you’re
changing the amount from what was previously filed.
Check the box under “Treatment of item” if you’re reporting
the amount unchanged but are changing another
treatment of the item. Check both boxes if you’re changing
the amount and another treatment besides amount.

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TEFRA partner filing an AAR. If a partner in a TEFRA
partnership is filing an AAR to change items associated
with its investment in the TEFRA partnership that were
reported on its original return, do the following.
1. Determine the required changes to be made.
2. Complete Form 8082 to identify the changes being
made.
a. On Form 8082, check box (b) under Part I, line 1.
b. See Lines 8 Through 11 below for how to complete
Part II, columns (a) through (e).
3. Complete the applicable amended return.
4. File Form 8082 along with the applicable amended
return and attach any other supporting documents
required.

Partner filing a notice of inconsistent treatment for a
Schedule K-1 received from a TEFRA partnership. If
a partner doesn’t receive a Schedule K-1 from a TEFRA
partnership or does receive a Schedule K-1 but disagrees
with some or all of the reported treatment and/or amounts,
it may file a notice of inconsistent treatment by doing the
following.
1. On Form 8082, check box (a) under Part I, line 1.
2. See Lines 8 Through 11 below for how to complete
Part II, columns (a) through (e).
3. File Form 8082 along with the applicable return and
attach any other supporting documents required.

Lines 8 Through 11
Note. Lines 8 through 11 are only required if reporting a
change to the amount or treatment of a monetary number.
Column (a).
AAR. Enter the line number and description from the
form for which you’re making the change. For example, if
you’re changing the amount reported on Schedule K,
line 1, enter “Schedule K, line 1.”
10

Note. If you check only “Treatment of item,” you don't
need to complete columns (d) and (e).
Column (c).
AAR. Report the amount you previously reported for the
item listed in column (a).

Column (d). Enter the amount you’re reporting as the
correct amount in column (d).
Column (e). Enter the net increase or decrease for each
line being changed in column (e). Enter as a positive the
amount by which column (d) exceeds column (c) or enter
as a negative the amount by which column (c) exceeds
column (d). Use parentheses around all amounts that are
negative. Explain the reason for the change (increase or
decrease) in Part III.

Part III—Explanations

Explain in detail the reasons you're reporting a corrected
amount or item as follows.
• If the pass-through entity hasn’t filed a tax return by the
time you're required to file your tax return, enter as the
explanation, “Partnership (S corporation, Estate, Trust, or
REMIC) return not filed.”
• If the pass-through entity didn’t give you a
Schedule K-1, Schedule K-3 (and the pass-through entity
was required to provide one to you according to the
instructions for Schedule K-2), Schedule Q, and/or foreign
trust statement by the time you're required to file your tax
return, enter as the explanation, “Schedule K-1
(Schedule K-3, Schedule Q, and/or foreign trust
statement) not received.”

BBA AAR
Name and Identifying Number

Enter the legal name of the entity and identifying number
on the appropriate lines.

Part I—General Information
Line 1
Check box (b) if you're filing an AAR on which you're
requesting a change in the amount or treatment of any
item from the way you reported it on your return as
originally filed or as you later amended it.

For Partnership Tax Years Beginning After 2017
and Partnerships Electing Into BBA for Tax Years
Beginning After November 2, 2015, and Before
January 1, 2018
BBA AAR. All partnerships with tax years beginning after
2017 are subject to the centralized partnership audit
regime unless an eligible partnership makes a valid
Instructions for Form 8082 (Rev. Dec. 2024)

election under section 6221(b) to elect out of the
centralized partnership audit regime.
Partnerships electing into BBA for tax years beginning
after November 2, 2015, and before January 1, 2018, are
also subject to the centralized partnership audit regime.
Partnerships that are subject to the centralized
partnership audit procedures of sections 6221 through
6241 are referred to as “BBA partnerships.” A partnership
with a tax year beginning after 2017 that isn't subject to
BBA proceedings because it has made a valid election
under section 6221(b) is referred to as a “non-BBA
partnership.” An AAR filed by a BBA partnership is a BBA
AAR.
If a BBA partnership files an AAR and it needs to make
its partners aware of their allocable shares of adjustments,
it will furnish to each partner for the reviewed year a Form
8986 reflecting the partner's share of the adjustments
(and shouldn't provide amended Schedules K-1 or K-3).
The partnership is also required to file with the AAR any
Forms 8986 required to be furnished to partners along
with Form 8985. See the instructions for these forms for
further information.
The partnership will need to furnish such statements to
make its partners aware of their allocable shares of
adjustments when (a) the adjustments in the BBA AAR
result in an IU of zero or less than zero, or the adjustments
don't result in an IU; or (b) the adjustments in the BBA
AAR do result in an IU greater than zero but (as an
alternative to payment) the BBA partnership makes a valid
election under section 6227(b)(2) to have each reviewed
year partner take its share of adjustments into account.
See items B, C, and D that follow.
Item A. If “Yes” is checked, complete Form 8979 and
attach it to the AAR. See the Instructions for Form 8979.
Item B. BBA partnerships filing an AAR will need to
determine if the partnership adjustments result in an IU.
See Figuring the IU, later, for information on how to figure
the IU. The BBA partnership should consider all available
guidance issued by the IRS in making a determination of
whether or not the AAR results in an IU. Also see IU Under
the Centralized Partnership Audit Regime, later, for
discussion of the IU.

in an IU (for example, the adjustments in the BBA AAR
result in an IU of zero or less than zero; or there is a net
negative adjustment).
The partnership is also required to file with the AAR all
Forms 8986 furnished to partners and Form 8985. See the
instructions for these forms for further information.

Note. An IU calculation must always be made and
presented on the AAR. This even applies when the IU is
zero or less than zero, or the adjustments don't result in an
IU. See Figuring the IU, later, under Part III for information.
Item C1. If the adjustments contained in the BBA AAR
result in an IU, the partnership must pay the IU at the
same time the AAR is filed. However, under section
6227(b)(2), the partnership can elect to have its reviewed
year partners take the adjustments into account. This is an
election to push out the adjustments to the partners as an
alternative to payment of the IU. See section 6226(a)(2)
for details. If this valid election is made, the partnership is
no longer liable for the IU.

If the IRS determines the election is invalid, it may
assess an IU on the partnership. In such a case, if
CAUTION the partnership filed its IU calculation and Form
8980 to request permitted modifications be applied to the
IU, those modifications will be considered in making such
assessment.

Note. The BBA partnership doesn't furnish Schedules
K-1 to its partners when filing a BBA AAR. Instead, it'll
provide Forms 8986.
Item D. Each reviewed year partner is required to take
into account its share of adjustments requested in a BBA
AAR if the partnership adjustments result in a positive IU
and the partnership makes the alternative to payment
election discussed under Item C1, earlier. Additionally,
each reviewed year partner is required to take into
account its share of any adjustments requested in a BBA
AAR resulting in an IU of zero or less than zero, or that
don't result in an IU. The determination of whether or not
an adjustment results in an IU amount is discussed earlier
under Item B.
The partnership is required to furnish each reviewed
year partner with a Form 8986 reporting its share of the
BBA AAR adjustments. The PR must attest to the
partnership’s compliance with this requirement. The PR
will manually sign Form 8082 under item D to declare
under penalties of perjury that all statements have been
provided to the reviewed year partners as required by
these instructions. If filing electronically, Form 8082 should
be attached as a PDF to Form 1065.
Item E. Under section 6227(b)(1), the partnership may
modify the IU resulting from adjustments reported in a
BBA AAR in accordance with the provisions under section
6225(c), disregarding the provisions under paragraphs
(2), (7), and (9). Any modification made to the IU under
section 6227(b)(1) must be disclosed and fully explained
on Form 8980 included with the AAR.

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If the IRS determines the election is invalid, it may
assess an IU on the partnership.

CAUTION

Item C2. The partnership will need to furnish Forms
8986 to each reviewed year partner reflecting the partner's
share of adjustments for when the adjustments don't result
Instructions for Form 8082 (Rev. Dec. 2024)

Note. If the partnership makes a valid election to push out
the adjustments to the partners as alternative to payment
of the IU, the modifications to the IU are disregarded and
aren’t included on the statements provided to the
partners.

!

Part II—Inconsistent or Administrative
Adjustment Request (AAR) Items

If a BBA partnership is filing an AAR to change items that
were reported on its original return, do the following.
1. Determine the required changes to be made.
2. Complete Form 8082 to identify the changes being
made.
a. On Form 8082, check box (b) under Part I, line 1.
b. See Lines 8 Through 11, later, for how to complete
Part II, columns (a) through (e).
11

3. Figure an IU and determine if there are any
adjustments that don't result in an IU.
4. Determine if you'll pay the IU or push out the
adjustments to the partners.
a. If paying an IU, complete Form 1065 and report the
IU appropriately. Include any permitted modifications
that you would like applied to the IU and include a
completed Form 8980 with your filing. Complete
Forms 8985 and 8986 (pushout package) pertaining to
the adjustments that don't result in an IU (if
applicable).
b. If pushing out all the adjustments to the reviewed
year partners, complete Form 1065 (see
Administrative Adjustment Request (AAR) in the
Instructions for Form 1065). Also complete Forms
8985 and 8986. Don't include Schedules K-1 because
they aren't appropriate for a BBA AAR.

Column (e). Enter the net increase or decrease for each
line being changed in column (e). Enter as a positive the
amount by which column (d) exceeds column (c) or enter
as a negative the amount by which column (c) exceeds
column (d). Use parentheses around all amounts that are
negative. Explain the reason for the change (increase or
decrease) in Part III.

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Note. If the partnership elects to push out the
adjustments and the IRS determines the election is
invalid, it may assess an IU on the partnership. In such
a case, if the partnership filed its IU calculation and
Form 8980 to request permitted modifications be
applied to the IU, those modifications will be
considered in making such assessment.
5. File Form 8082 along with Form 1065, and attach
any other supporting documents required, including
copies of Forms 8985 and 8986 (if applicable).
6. If applicable, distribute the Forms 8986 to reviewed
year partners according to the Form 8986 instructions.

Subject to the particular filing rules, an AAR can be filed
by partnerships subject to BBA proceedings (BBA AAR).
An AAR can also be filed by the partnership-partners in a
BBA partnership (but only for the purpose of providing
notice of inconsistent treatment with the AAR). See
Regulations section 301.6227-1(a) referring to
Regulations section 301.6222-1.

Lines 8 Through 11
Note. Lines 8 through 11 are only required if reporting a
change to the amount or treatment of a monetary number.
Column (a).
AAR. Enter the line number and description from the
form for which you're making the change. For example, if
you're changing the amount reported on Schedule K,
line 1, enter “Schedule K, line 1.”
Column (b).
AAR. Check the box under “Amount of item” if you're
changing the amount from what was previously filed.
Check the box under “Treatment of item” if you're reporting
the amount unchanged but are changing another
treatment of the item. Check both boxes if you're changing
the amount and another treatment besides amount.
Column (c).
AAR. Report the amount you previously reported for the
item listed in column (a).
Column (d). Enter the amount you're reporting as the
correct amount in column (d).

12

Part III—Explanations

Explain in detail the reasons you're reporting an
inconsistent or corrected amount or item as follows.
• If the pass-through entity hasn’t filed a tax return by the
time you're required to file your tax return, enter as the
explanation, “Partnership (S corporation, Estate, Trust, or
REMIC) return not filed.”
• If the pass-through entity didn’t give you a
Schedule K-1, Schedule K-3 (and the pass-through entity
was required to provide one to you according to the
instructions for Schedule K-2), Schedule Q, and/or foreign
trust statement by the time you're required to file your tax
return, enter as the explanation, “Schedule K-1
(Schedule K-3, Schedule Q, and/or foreign trust
statement) not received.”

IU Under the Centralized Partnership Audit
Regime

BBA AARs must always include a computation of the IU
(even when the IU is zero or less than zero, or the
adjustments don't result in an IU), as determined under
section 6225(b). See Figuring the IU, later, for information
on how to figure the IU. Also go to How to figure an
imputed underpayment. Documentation should be
included with the AAR that supports the computation of
the IU amount. The BBA partnership should consider all
available guidance issued by the IRS when figuring the IU
amount for an AAR. If the calculated IU amount results in
an amount greater than zero and the partnership doesn't
elect under section 6227(b)(2) to have its reviewed year
partners take the adjustments into account, the IU amount
should be reported on Form 1065, page 1, line 26.

If the adjustments requested in the AAR result in an IU,
generally the partnership must pay the IU. Adjustments
requested in the AAR that don't result in an IU must be
taken into account by each reviewed year partner as if the
partnership had made an election under section 6227(b)
(2), but only with regard to those adjustments that don't
result in an IU. In this instance, see Forms 8985 and 8986
and the related instructions for reporting amounts not
included in the IU.
When filing an AAR, the partnership may elect under
section 6227(b)(2) to have the reviewed year partners take
into account adjustments resulting in an IU. If the
partnership makes the election, the partnership isn't liable
for, nor required to pay, the IU related to the adjustments.
Additionally, if the IU calculation results in an amount that
is zero or less than zero, or the adjustments don't result in
an IU, then all adjustments are taken into account by the
reviewed year partners. However, the partnership may
have withholding and reporting obligations under
chapter 3 or 4 with respect to the adjustments taken into
account by the reviewed year foreign partners. See Forms
Instructions for Form 8082 (Rev. Dec. 2024)

8985 and 8986 and their related instructions for how to
report these adjustments to reviewed year partners.
If the partnership validly elects under section 6227(b)
(2) to have its reviewed year partners take all the
adjustments into account, all modifications by the
partnership (that would have been allowed had the
partnership paid an IU) aren’t allowed and are
disregarded.

Credit grouping. Any adjustment to a PRI that is
reported or could be reported by a partnership as a credit
on the partnership’s return, including a reallocation
adjustment to such PRI, is placed in the credit grouping.

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Under section 6227(b)(1), the partnership may modify
the IU resulting from adjustments reported in a BBA AAR
in accordance with the provisions under section 6225(c),
disregarding the provisions under sections 6225(c)(2), (7),
and (9). Any modification made to the IU under section
6227(b)(1) must be disclosed and fully explained in
documentation included with the AAR. If modifications are
applied to the IU, complete and attach Form 8980 and
report the modified IU amount on Form 1065, page 1,
line 26.
Note. Regarding modifications, see Item E under Part I,
earlier.

If the partnership elects under section 6227(b)(2)
to have its reviewed year partners take all the
CAUTION adjustments into account and the IRS determines
the election is invalid, it may assess an IU on the
partnership. In such a case, if the partnership filed its IU
calculation and Form 8980 to request permitted
modifications be applied to the IU, those modifications will
be considered in making such assessment.

!

don't result in an IU are taken into account by the reviewed
year partners in accordance with Regulations section
301.6227-3.

The applicability of interest and penalties is discussed
above. The BBA AAR may include a prepayment for
interest and penalties. If making prepayments, the AAR
should include documentation that supports the
calculations. A payment made with Form 1065 should
detail the portions of the payment that are for the IU, the
prepaid estimated interest, and the prepaid estimated
penalties. The total of all three should be reflected on
Form 1065, page 1, line 26.

Under section 6232(b), partnerships filing a BBA AAR
that have adjustments that result in an IU, and don't elect
the alternative to payment of the IU (by not electing to
push out the adjustments to the reviewed year partners),
must pay the IU, which should be shown on Form 1065,
page 1, line 26, at the same time that the AAR is filed.
When paying by check, include the name of the
partnership, “Form 1065,” the TIN of the partnership, the
tax year, and “BBA AAR Imputed Underpayment.” Checks
must be made payable to “United States Treasury” and
included with the BBA AAR. If making an electronic
payment, choose the payment description “BBA AAR
Imputed Underpayment” from the list of payment types.

Figuring the IU
Definitions
Adjustments not resulting in an IU. After grouping,
subgrouping, and netting the adjustments, the result of
netting with respect to any grouping or subgrouping that
includes a particular partnership adjustment is a net
negative adjustment or the IU calculation results in an
amount that is zero or less than zero. Any adjustments that
Instructions for Form 8082 (Rev. Dec. 2024)

Creditable expenditure grouping. Any adjustment to a
PRI where any person could take the item that is adjusted
(or item as adjusted if the item wasn’t originally reported
by the partnership) as a credit, including a reallocation
adjustment to a creditable expenditure, is placed in the
creditable expenditure grouping.

Negative adjustment. A negative adjustment is any
adjustment that is a decrease in an item of gain or income;
an increase in an item of loss or deduction; an increase in
an item of credit or creditable expenditure; a decrease in
an item of tax, penalty, addition to tax, or additional
amount for which the partnership is liable under chapter 1;
or a decrease to an IU calculated by the partnership for
the tax year.
Net negative adjustment. Any amount which results
from netting adjustments within a grouping or subgrouping
that isn't a net positive adjustment. A net negative
adjustment includes a negative adjustment that wasn’t
netted with any other adjustment.

Net positive adjustment. An amount that is greater than
zero which results from netting adjustments within a
grouping or subgrouping. A net positive adjustment
includes a positive adjustment that wasn’t netted with any
other adjustment. A net positive adjustment includes a net
decrease in an item of credit (or creditable expenditure).
Positive adjustment. A positive adjustment is any
adjustment that isn't a negative adjustment.
Reallocation grouping. In general, any adjustment that
allocates or reallocates a PRI to and from a partner or
partners is a reallocation adjustment, except for an
adjustment to a credit or to a creditable expenditure. Each
reallocation adjustment generally results in at least two
separate adjustments, each of which becomes a separate
subgrouping.
Residual grouping. Any adjustment to a PRI that
doesn’t belong in the reallocation, credit, or creditable
expenditure grouping is placed in the residual grouping.
This grouping also includes any adjustment to a PRI that
derives from an item that wouldn’t have been required to
be allocated by the partnership to a partner under section
704(b), such as an adjustment to a liability amount on the
balance sheet.
Subgrouping. Each adjustment is subgrouped
according to how the adjustment would be required to be
taken into account separately under section 702(a). In
general, a subgrouping follows Schedules K, K-1, K-2,
and K-3 line items, including any alpha codes related to a
Schedule K-1, K-2, or K-3 line item.
Total netted partnership adjustments (TNPA). The
sum of all net positive adjustments in the reallocation
grouping and the residual grouping.
13

Formula for Figuring the IU
Figuring the IU
TNPA x rate* =
+ Sum of net positive adjustments
to creditable expenditure and
credit groupings:

Credit grouping.
• Generally, a decrease in credits is treated as a positive
adjustment, and an increase in credits is treated as a
negative adjustment.
• A reallocation adjustment relating to the credit grouping
is placed into two separate subgroupings and won’t be
netted together nor will they be netted with other credit
adjustments.

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= Total IU

* Highest rate in effect for the reviewed year under section 1 or 11.

The process of taking the adjustments shown on the
AAR and inputting them into the formula shown in the
previous table requires an understanding of the concepts
of grouping, subgrouping, and netting. There are seven
steps necessary in figuring an IU. The first three steps
focus on grouping, subgrouping, and netting.

Steps in Figuring the IU
Step 1—Grouping

Place each adjustment into one of four groupings:
reallocation, credit, creditable expenditure, and residual
groupings.

Note. Under Regulations section 301.6225-1(b)(4), solely
for purposes of calculating any IU, a partnership that files
an AAR may treat a positive adjustment as zero if the
positive adjustment is related to, or results from, a positive
adjustment to another item. The IRS may determine that
the adjustment should not have been treated as zero by
the partnership in its calculation of the IU. Go to How to
figure an imputed underpayment.
Reallocation grouping. A reallocation adjustment
generally consists of at least two adjustments, one
positive and one negative, with each in a separate
subgrouping.
• One part of the reallocation adjustment reverses the
effect of the improper allocation of a PRI.
• The other part of the adjustment makes the proper
allocation of the PRI.
• Under the AAR rules, if one of the reallocation
adjustments is negative, such negative adjustments must
be pushed out to the proper partner(s).

Don't net reallocation adjustments. As each part of
a reallocation adjustment is placed in a separate
CAUTION subgrouping within the reallocation grouping,
those adjustments can’t be netted in accordance with the
netting rules.

!

Example. $100 of ordinary income is being
reallocated from Partner A to Partner B. For purposes of
figuring the IU, there will be two adjustments, each in a
separate subgrouping: a negative adjustment of $100
(reversing improper allocation to Partner A) and a positive
adjustment of $100 (making proper allocation to Partner
B). These two adjustments can’t be netted. As a result, the
total net positive adjustment in the reallocation grouping is
$100 and will be included in the TNPA.
14

Creditable expenditure grouping.
• Generally, a decrease in creditable expenditures is
treated as a positive adjustment to credits, and an
increase in creditable expenditures is treated as a
negative adjustment.
• A reallocation adjustment relating to a creditable
expenditure grouping is placed into two separate
subgroupings and won’t be netted together.
• A creditable expenditure is treated in this manner even
if the partners claimed a deduction in lieu of a credit.
• Each adjustment to a creditable expenditure is
subgrouped based upon the separate category of income
to which the creditable expenditure relates and to account
for any different allocation of the creditable expenditure
between partners. Two or more adjustments to creditable
expenditures are included within the same subgrouping
only if each adjustment relates to creditable expenditures
in the same separate category, and each adjusted PRI
would be allocated to the partners in the same ratio had
those items been properly reflected on the originally filed
partnership return.
Residual grouping. The residual grouping contains all
adjustments that don't fit into one of the other groups.

Recharacterization adjustments. A recharacterization
adjustment will generally result in at least two separate
adjustments within the residual grouping.
• One adjustment reverses the improper characterization
of the PRI.
• The other adjustment makes the proper
characterization of the PRI.
• The adjustments that result from a recharacterization
are placed into separate subgroupings.

Step 2—Subgrouping
Determine if any adjustment, within one of the four
groupings, needs to be subgrouped. Each adjustment is
subgrouped according to how the adjustment would be
required to be taken into account separately under section
702(a). If any adjustment could be subject to any
preference, limitation, or restriction under the Code (or not
allowed, in whole or in part, against ordinary income) if
taken into account by any person, the adjustment is
placed in a separate subgrouping from all other
adjustments within the grouping.
Generally, each separate line item of Schedules K, K-1,
K-2, and K-3 or return schedule (that is, Schedule L, etc.)
represents a separate and distinct subgrouping.
Example. Adjustments to ordinary income must be
placed in a different subgrouping than capital gain income
or interest income because each of those items is
required to be separately stated under section 702(a).
Instructions for Form 8082 (Rev. Dec. 2024)

• Subgroupings generally reflect a line item from
Schedules K, K-1, K-2, and K-3 including any
subcategories of those lines (for example, alpha codes
per the Schedule K-1 instructions or activities broken out
via attached statements). If any line item on Schedules K
or K-1 or other schedules consists of multiple items and
the components are required to be taken into account
separately under the Code, regulations, forms,
instructions, or other IRS guidance, then such line item
must be further subgrouped.

• All adjustments within a subgrouping are netted to
determine whether there is a net positive adjustment or
net negative adjustment for that subgrouping.
• Net positive adjustments from subgroupings or positive
adjustments within a grouping (if subgroupings are
unnecessary) are netted to determine the net positive
adjustment for that grouping. Net negative adjustments
from subgroupings within a grouping are netted to
determine the net negative adjustment for that grouping.

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Example. 2019 Schedule K-1, box 13, code A (cash
contributions 60%), and box 13, code B (cash
contributions 30%), are two separate subgroupings.
• The ordinary income (loss) amount reported on
Schedule K, line 1, and in box 1 of Schedule K-1 is
sourced from Form 1065, page 1, and is a net amount
consisting of various page 1 line items of income and
expenses. Although those separate page 1 line items are
distinct items of income and expense, if they are
appropriately netted and included on Schedule K, line 1,
and in box 1 of Schedule K-1, the net amount will be
considered a single subgrouping, except when such
amount is required to be separately allocated, such as
when the partnership has more than one trade or
business. If the partnership has more than one trade or
business activity, the net income (loss) from each
separate activity must be reported on Schedule K-1. Each
separate activity will constitute a separate subgrouping
and it must be determined which activity an adjustment to
the page 1 item of income and expense relates to for
subgrouping purposes.
• If you have a negative adjustment along with a positive
adjustment in the same line item of Schedules K and K-1,
you must consider whether they may be properly netted at
the partnership level and whether they are required to be
taken into account separately by any partner. They may be
subject to a limitation or preference under the Code before
you can place them in the same subgrouping (for
example, passive and nonpassive activities).
• A negative adjustment that isn't otherwise required to
be placed in its own subgrouping must be placed in the
same subgrouping as another adjustment if the negative
adjustment and the other adjustment would have been
properly netted at the partnership level and such netted
amount would have been required to be allocated to the
partners of the partnership as a single item for purposes
of section 702(a) or other provision of the Code and
regulations.

Step 3—Netting
Net all adjustments within each of the groupings and
subgroupings.
• Positive adjustments may be netted with other positive
adjustments only if they are in the same grouping.
Negative adjustments may be netted with other negative
adjustments only if they are in the same grouping.
• Positive and negative adjustments may only be netted
against each other if they are in the same subgrouping.
• An adjustment in one grouping or subgrouping may not
be netted against an adjustment in any other grouping or
subgrouping.
Instructions for Form 8082 (Rev. Dec. 2024)

Step 4—Figure the Total Netted Partnership
Adjustments (TNPA)

• Each net positive adjustment with respect to a particular
grouping or subgrouping in the residual or reallocation
grouping that results after netting the adjustments is
included in the calculation of the TNPA.
• Each net negative adjustment with respect to a residual
or reallocation grouping or subgrouping that results after
netting the adjustments is excluded from the calculation of
the TNPA because those adjustments don't result in an IU.

Note. If a positive adjustment to an item is reflected in
positive adjustments to other items, the positive
adjustment of equal or lesser magnitude that is reflected
may be treated as zero solely for purposes of calculating
any IU.

Step 5—Determine the Highest Tax Rate in Effect
Under Section 1 or 11 in the Reviewed Year
Step 6—Determine the Sum of Net Positive
Adjustments to Creditable Expenditure and Credit
Groupings That Will Increase the Product of the
TNPA Multiplied by the Highest Rate in Effect

• A net decrease to creditable expenditures is treated as
a net positive adjustment to credits and increases the
product of the TNPA multiplied by the highest tax rate in
effect. A net increase to creditable expenditures is treated
as a net negative adjustment (including net negative
adjustments resulting from a creditable expenditures
reallocation adjustment) that’s excluded from the
calculation of the TNPA and is an adjustment that doesn’t
result in an IU.
• For the credit grouping, a net positive adjustment will
increase the product of the TNPA multiplied by the highest
tax rate in effect. A net negative adjustment, including net
negative adjustments resulting from a credit reallocation
adjustment, will be treated as an adjustment that doesn’t
result in an IU.

15

Step 7—Figure the IU Based on the Results of
Steps 4 Through 6 and Insert Those Results Into
the IU Formula
Figuring the IU
TNPA x rate* =

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+ Sum of net positive adjustments
to creditable expenditure and
credit groupings:

= Total IU

* Highest rate in effect for the reviewed year under section 1 or 11.

Paperwork Reduction Act Notice. We ask for the
information on this form to carry out the Internal Revenue
laws of the United States. You're required to give us the
information. We need it to ensure that you're complying
with these laws and to allow us to figure and collect the
right amount of tax.
You aren’t required to provide the information requested
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16

Comments and suggestions. If you have suggestions
for making Form 8082 and/or these instructions simpler,
we would be happy to hear from you. You can send us
comments through IRS.gov/FormComments. Or, you can
write to the Internal Revenue Service, Tax Forms and
Publications Division, 1111 Constitution Ave. NW,
IR-6526, Washington, DC 20224. Don’t send Form 8082
to this address. Instead, see How and When To File,
earlier.

Instructions for Form 8082 (Rev. Dec. 2024)