8082 Notice of Inconsistent Treatment or Administrative Adjus

Form

8082

(Rev. October 2025)
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, 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

Check applicable box.
(a)
Notice of inconsistent treatment (go to line 2)
(b)
BBA AAR—for partnership tax years beginning after December 31, 2017 (or for partnerships that elected
into BBA for tax years beginning after November 2, 2015, and before January 1, 2018) (go to item A below)
Note. For AAR filings pertaining to a Non-BBA partnership, see the instructions.
A

B
C1

Yes No

Is the partnership revoking the immediately preceding partnership representative (PR) (and/or designated
individual (DI), if applicable) and designating a successor (including the appointment of a DI, 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 PR declares, under penalties of perjury, that all statements have
been provided to the reviewed year partners as required by the instructions.

Date

Signature of reviewed year PR (or DI, if the PR is an entity)

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)
S Corporation (b)
Estate (c)
Trust (d)
REMIC (e)
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

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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
(c) Amount as shown on
in, or AAR is to
Schedule K-1, Schedule Q, or
correct (check boxes
similar statement; a foreign
that apply)
trust statement; or your
return, whichever applies
Amount of Treatment
(see instructions)
item
of item

(d) Amount you are
reporting

(e) Amount of change
(column (d) less column (c))

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

Cat. No. 49975G

Form 8082 (Rev. 10-2025) Created 4/15/25

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. 10-2025)

Part III

Form 8082 (Rev. 10-2025)