Federal Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)

Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)
Form 8082 (Rev. October 2023)
Form

8082

(Rev. October 2023)
Department of the Treasury
Internal Revenue Service

Notice of Inconsistent Treatment or Administrative
Adjustment Request (AAR)
(For use by partners, S corporation shareholders, estate and domestic trust beneficiaries, foreign
trust owners and beneficiaries, REMIC residual interest holders, TMPs, and PRs.)

1

Attachment
Sequence No. 84

Go to www.irs.gov/Form8082 for instructions and the latest information.
Identifying number

Name(s) shown on return

Part I

OMB No. 1545-0074

General Information
Yes No

Check boxes that apply.
(a)
Notice of inconsistent treatment (go to line 2)
(b)
AAR (choose one below—see instructions)
For partnership tax years beginning before January 1, 2018 (unless electing into BBA)
TEFRA AAR
ELPs/REMICs
For partnership tax years beginning after December 31, 2017 (or that elected into BBA for tax years beginning
after November 2, 2015, and before January 1, 2018)
BBA AAR—go to item A below
A

B
C1

Is the partnership revoking the immediately preceding partnership representative (and/or designated
individual, if applicable) and designating a successor (including the appointment of a designated
individual, if applicable) at the same time that the AAR is being filed? If “Yes,” attach Form 8979 . . .
Do the adjustments on the AAR result in an imputed underpayment (IU) for the reviewed year? If “Yes,”
go to item C1. If “No,” go to item D . . . . . . . . . . . . . . . . . . . . . . .
Is the partnership making an election under section 6227(b)(2) to have the adjustments taken into account
by the reviewed year partners? If “Yes,” go to item D. If “No,” go to item C2 . . . . . . . . . .

C2

Are there also adjustments that do not result in an IU? (An adjustment does not result in an IU if the result
of netting with respect to any grouping or subgrouping that includes the particular adjustment is a net
negative adjustment.) If “Yes,” go to item D and then answer item E. If “No,” go to item E . . . . .

D

If the partnership is required to provide statements to the reviewed year partners containing their share of
the adjustments, by signing below, the partnership representative declares, under penalties of perjury,
that all statements have been provided to the reviewed year partners as required by the instructions.

Date

Partnership Representative Name (or designated individual, if appropriate)

2

E Is the partnership applying modifications to the IU? If “Yes,” attach Form 8980 .
Identify type of pass-through entity in which you are a partner, shareholder, or member.

3

(a)
(e)
(f)
TEFRA Partnership (b)
S Corporation (c)
Estate (d)
Trust
REMIC
BBA Partnership
Employer identification number of pass-through entity 5 Internal Revenue Service Center where pass-through entity filed its return

4

Name, address, and ZIP code of pass-through entity

Part II

6 Tax year of pass-through entity
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7 Your tax year
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to

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Inconsistent or Administrative Adjustment Request (AAR) Items

(a) Description of inconsistent or AAR items
(see instructions)

(b) Inconsistency is in,
or AAR is to correct
(check boxes that apply)
Amount of
item

Treatment
of item

(c) Amount as shown on
Schedule K-1, Schedule Q, or
similar statement; a foreign
trust statement; or your return,
whichever applies (see
instructions)

(d) Amount you are reporting

(e) Difference between
(c) and (d)

8
9
10
11
For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 49975G

Form 8082 (Rev. 10-2023)

Page 2
Explanations—Enter the Part II item number before each explanation. Show how the IU was calculated
and how modifications were applied.

Form 8082 (Rev. 10-2023)

Part III

Form 8082 (Rev. 10-2023)