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.) 

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

OMB No. 1545-0074 

Attachment 

Sequence No. 84 

Name(s) shown on return Identifying number 

Part I General Information 

1 Check boxes that apply.

(a) Notice of inconsistent treatment (go to line 2)

(b) AAR (choose one below—see instructions)

Yes No 

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 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 . . .

B 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 . . . . . . . . . . . . . . . . . . . . . . .

C 1 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 . . . . . . . . . .

C 2 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.

Partnership Representative Name (or designated individual, if appropriate) Date

E Is the partnership applying modifications to the IU? If “Yes,” attach Form 8980 . . . . . . . . .

2 Identify type of pass-through entity in which you are a partner, shareholder, or member.

(a) TEFRA Partnership (b) S Corporation (c) Estate (d) Trust (e) REMIC (f) BBA Partnership 

3 Employer identification number of pass-through entity 

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

5 Internal Revenue Service Center where pass-through entity filed its return

6 Tax year of pass-through entity 

/ / to / / 

7 Your tax year 

/ / to / / 

Part II 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) 

(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) 

 Amount of 

item

Treatment 

of item 

8

9

10 

11 

For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 49975G Form 8082 (Rev. 10-2023) 
Form 8082 (Rev. 10-2023) Page 2 

Part III 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)