Installment Payments of Section 1446 Tax

for Partnerships Form 8804-W OMB No. 1545-1991

(WORKSHEET)

(Keep for the partnership’s records—Do not send to the Internal Revenue Service.)

Department of the Treasury

Internal Revenue Service

1 Foreign partner’s allocable share of effectively connected taxable

income (ECTI) expected for the tax year:

2 2

3 3

4 4

5 5

6 6

Multiply line 1c by 35%

7

7

Multiply line 1f by 28%

8

8

Multiply line 1i by 25%

9

10

Add lines 2 through 5

Enter the total section 1446 tax that would be due for 2008, without regard to partner certificates, 

computed using the ECTI allocable to foreign partners for 2007

b

Enter the smaller of line 6 or line 7 (however, see Caution below). If the line 7 amount does not 

apply, enter the amount from line 6 on line 8

(a) (b) (c) (d)

Installment due dates (see

instructions) © 9

Enter 25% of line 8 in

columns (a) through (d)

unless the partnership uses

the annualized income

installment method or the

adjusted seasonal installment

method (see instructions)

11

For Paperwork Reduction Act Notice, see instructions. Cat. No. 40849X Form 8804-W (2008)

For calendar year 2008, or tax year beginning , 2008, and ending , 20 

Multiply line 1l by 15%

a

c

d

Net ordinary income 1a

Reduction to line 1a for valid partner certificates under Regulations

section 1.1446-6T (see instructions) 

Unrecaptured section 1250 gains (non-corporate partners only) 

Qualified dividend income and net long-term capital gains (including

net section 1231 gains) (non-corporate partners only) 

1b

1c

1d

Part I Determination of Installment Payments

28% rate gains (non-corporate partners only) 

Reduction to line 1d for valid partner certificates under Regulations

section 1.1446-6T (see instructions)

Subtract line 1b from line 1a 

Subtract line 1e from line 1d 

Reduction to line 1j for valid partner certificates under Regulations

section 1.1446-6T (see instructions)

Subtract line 1k from line 1j 

e

f

g

j

k

l

1e

1f

1g

1j

1k

1l

11 Enter certain amounts paid or

credited for each period (see

instructions)

12 Balance due. Subtract line

11 from line 10 12

10

Caution. If, for any installment payment, line 6 is smaller than line 7 and you enter that smaller line 6 amount, you will not

qualify for the prior year safe harbor when determining any penalty due on Schedule A (Form 8804) (see instructions).

Caution. This line 7 amount only applies if certain conditions are met (see instructions).

Note. If the aggregate line 6 amounts for all foreign partners is less than $500, the partnership is

not required to make estimated tax payments.

Reduction to line 1g for valid partner certificates under Regulations

section 1.1446-6T (see instructions) 

h

1h

i Subtract line 1h from line 1g 1i

2008
Form 8804-W (WORKSHEET) 2008 Page 2

Form 8804-W (2008)

15

16

17

17

First 4

months

First 6

months

First 9

months Entire year

Enter the foreign partner’s allocable share of ECTI for the

following periods:

18

a Tax year beginning in 2005 15a

b Tax year beginning in 2006 15b

c Tax year beginning in 2007 15c

Divide the amount in each column on line 13a by the amount 

in column (d) on line 15a. 16

Divide the amount in each column on line 13b by the amount 

in column (d) on line 15b.

Divide the amount in each column on line 13c by the amount 

in column (d) on line 15c. 18

24

25a

Multiply line 23 by 35%.

Divide the amount in columns (a) through (c) on line 15a by

the amount in column (d) on line 15a.

b

c

19 Add lines 16 through 18. 19

20

21a

24

20 Divide line 19 by 3.

25a

25b

25c

27

21a

28

Divide line 14 by line 20.

Divide the amount in columns (a) through (c) on line 15b by 

the amount in column (d) on line 15b.

Divide the amount in columns (a) through (c) on line 15c by

the amount in column (d) on line 15c.

26 Add lines 25a through 25c.

27 Divide line 26 by 3.

26

28 Multiply the amount in columns (a) through (c) of line 24 by

the amount in the corresponding column of line 27. In column 

(d), enter the amount from line 24, column (d).

22 Reduction to line 21c amount for valid certifications received

from the foreign partner under Regulations section 1.1446-6T. 22

23 Subtract line 22 from line 21c. If zero or less, enter -0-. 23

13

14

14

Adjusted Seasonal Installment Method (see instructions)

(Use this method only if the base period percentage for any 6 consecutive months is at least 70%.)

(a) (b) (c) (d)

First 11

months

First 8

months

First 5

months

First 3

months

Enter the foreign partner’s allocable share of ECTI for the

following periods:

a Tax year beginning in 2005 13a

b Tax year beginning in 2006 13b

c Tax year beginning in 2007 13c

Enter the foreign partner’s allocable share of ECTI for each

period for the tax year beginning in 2008 (see instructions

for the treatment of extraordinary items).

Part II

Check this box if the partnership has elected to attach a

schedule that expands lines 14 and 21 through 24 to reflect 

Reg. 1.1446-3(a)(2) (see instructions) ©

Extraordinary items (see instructions).

Combine lines 21a and 21b.

b

c

21b

21c
Form 8804-W (WORKSHEET) 2008 Page 3

36

37

39

38

4th

installment

3rd

installment

2nd

installment

1st

installment

39

If only Part II or Part III is completed, enter the amount in

each column from line 28 or line 35. If both parts are

completed, enter the smaller of the amounts in each column 

from line 28 or line 35. 36

Add the amounts in all preceding columns of line 42 (see instructions). 37

Adjusted seasonal or annualized income installments.

Subtract line 37 from line 36. If zero or less, enter -0-. 38

40

Enter 25% of line 6 in each column.

Subtract line 42 of the preceding column from line 41 of the 

preceding column.

41 Add lines 39 and 40.

40

Required installments. Enter the smaller of line 38 or line

41 here and on line 10.

41

42

Form 8804-W (2008)

Part IV Required Installments Under Part II and/or Part III

42

34 34

35 35

Applicable percentage. 25% 50% 75% 100%

Multiply line 33e by line 34.

33 Figure the tax on line 32 amounts as follows:

a

b

c

d

Multiply line 32c by 35%.

Multiply line 32f by 28%.

Multiply line 32i by 25%.

Multiply line 32l by 15%.

33a

33b

33c

33d

Add lines 33a through 33d. 33e

k Reduction to line 32j for valid partner certificates under

Regulations section 1.1446-6T (see instructions). 32k

l Subtract line 32k from line 32j. 32l

j Qualified dividend income and net long-term capital gains

(including net section 1231 gains) allocable to non-corporate

partners (multiply line 30d by line 31). 32j

e

Note. Complete lines 36 through 42 of one column before

completing the next column.

32 Foreign partner’s annualized allocable share of ECTI (see

instructions for the treatment of extraordinary items):

a

d

g

Net ordinary income (multiply line 30a by line 31).

28% rate gains allocable to non-corporate partners

(multiply line 30b by line 31).

Unrecaptured section 1250 gains allocable to

non-corporate partners (multiply line 30c by line 31).

32a

32d

32g

b Reduction to line 32a for valid partner certificates under

Regulations section 1.1446-6T (see instructions). 32b

c Subtract line 32b from line 32a. 32c

Annualized Income Installment Method (see instructions)

(a) (b) (c) (d)

29 Annualization periods (see instructions). 29

First

months

First

months

First

months

First

months

30 Enter the foreign partner’s allocable share of ECTI for each annualization

period (see instructions for the treatment of extraordinary items):

a

b

c

d

Net ordinary income.

28% rate gains (non-corporate partners only).

Unrecaptured section 1250 gains (non-corporate partners only).

Qualified dividends and net long-term capital gains (including

net section 1231 gains) (non-corporate partners only).

31 Annualization amounts (see instructions).

30a

30b

30c

30d

31

Part III

f Subtract line 32e from line 32d. 32f

e Reduction to line 32d for valid partner certificates under

Regulations section 1.1446-6T (see instructions). 32e

h Reduction to line 32g for valid partner certificates under

Regulations section 1.1446-6T (see instructions). 32h

i Subtract line 32h from line 32g. 32i
Form 8804-W (WORKSHEET) 2008 Page 4

Refiguring Estimated Section 1446 Tax

General Instructions

Section references are to the Internal Revenue Code unless

otherwise noted.

An immediate catch-up payment should be made to reduce the

amount of any penalty resulting from the underpayment of any

earlier installments, whether caused by a change in estimate,

failure to make a payment, or a mistake.

Specific Instructions

Who Must Make Estimated Section 1446

Tax Payments

When To Make Estimated Section 1446

Tax Payments

How To Make Estimated Section 1446

Tax Payments

Underpayment of Estimated Section

1446 Tax

Partnerships generally must make installment payments of

estimated section 1446 tax if they expect the aggregate tax on the

effectively connected taxable income (ECTI) that is allocable to all

foreign partners to be $500 or more.

The installments are due by the 15th day of the 4th, 6th, 9th, and

12th months of the partnership’s tax year. If any date falls on a

Saturday, Sunday, or legal holiday, the installment is due on the

next regular business day.

A partnership that does not make estimated section 1446 tax

payments when due may be subject to an underpayment penalty

for the period of underpayment. See Schedule A (Form 8804) for

details.

A partnership that is required to make an installment payment of

section 1446 tax must file Form 8813, Partnership Withholding

Tax Payment Voucher (Section 1446). Furthermore, the

partnership is generally required to notify each foreign partner of

the section 1446 tax paid on the partner’s behalf within 10 days of

the installment payment due date. See Regulations section

1.1446-3(d) and the Instructions for Forms 8804, 8805, and 8813

for more information.

If, after the partnership figures and pays estimated section 1446

tax, it finds that its section 1446 tax liability for the year will be

more or less than originally estimated, it may have to refigure its

required installments. If earlier installments were underpaid, the

partnership may owe a penalty for underpayment of estimated

tax.

Part I—Determination of Installment

Payments

Line 7—Prior Year Safe Harbor

Enter the total section 1446 tax that would be due for 2008,

without regard to partner certificates, computed using the ECTI

allocable to foreign partners for 2007. With respect to the

partnership’s first installment payment, if the 2007 Form 8804 has

not yet been filed, an estimate is acceptable. However, if the

partnership later determines that this estimate is incorrect, see

Refiguring Estimated Section 1446 Tax above.

Complete line 7 only if all of the following apply:

● The prior tax year consisted of 12 months,

● The partnership timely files (including extensions) a U.S. return

of partnership income (e.g., Form 1065) for the prior year, and

● The amount of ECTI for the prior tax year is not less than 50%

of the ECTI expected for the current tax year. Furthermore, the

Form 8804 on which the current year ECTI will be reported must

be timely filed.

If any of the above does not apply, skip line 7 and enter the

amount from line 6 on line 8.

If the partnership qualifies to use the prior year safe harbor and

chooses that method, it must use that method to pay each of its

installments during the tax year. Furthermore, for each installment

payment, the average of that installment and prior installments

during the tax year must be at least 25% of the amount that

satisfies the partnership’s section 1446 tax liability under the prior

year safe harbor. If the partnership does not satisfy both of these

requirements, it will not qualify for the prior year safe harbor when

determining any penalty due on Schedule A (Form 8804).

Lines 1b, 1e, 1h, and 1k. Enter the reduction amounts by reason

of valid certificates received from foreign partners under

Regulations section 1.1446-6T. See Certification of Deductions

and Losses in the Instructions for Forms 8804, 8805, and 8813 for

additional information. Also see the last sentence of the

instructions for lines 1a, 1d, 1g, and 1j above for additional

information.

Complete Form 8804-W for each installment payment of section

1446 tax based on the information available at the time of the

installment payment.

If the partnership has net ordinary loss, net short-term capital

loss, or net 28% capital loss, each net loss should be netted

against the appropriate categories of income and gain to

determine the amounts of income and gain to be entered on lines

1d, 1g, and 1j, respectively. See section 1(h) and Notice 97-59,

1997-45 I.R.B. 7, for rules for netting gains and losses. In addition,

if the partnership has received any certificates under Regulations

section 1.1446-6T, then the netting rules of section 1(h) and

Notice 97-59 must be considered in determining the category of

income such items offset.

Lines 1 through 6—Current Year Safe Harbor

Lines 1a, 1d, 1g, and 1j. To determine the foreign partner’s

allocable share of ECTI, see Effectively Connected Taxable

Income in the Instructions for Forms 8804, 8805, and 8813. With

respect to lines 1d, 1g, and 1j, enter the specified types of ECTI if

such partner would be entitled to use a preferential rate on such

income or gain (see Regulations section 1.1446-3(a)(2)).

CAUTION

Regulations section 1.1446-6T sunsets in May 2008.

At the time these instructions went to print, the IRS

was contemplating issuing final regulations under

section 1.1446-6. Before completing Form 8804-W,

please check the Internal Revenue Bulletin or the Federal Register

to see if these regulations have been issued. If so, you must take

the final regulations into account before completing Form 8804-W.

What’s New

● Final regulations under section 6655 provide guidance with

respect to estimated tax requirements. These regulations are

applicable for tax years beginning after September 6, 2007.

● For partnerships that elect to use the annualized income

installment method, extraordinary items (as defined in Regulations

section 1.6655-2(f)(3)(ii)) generally must be taken into account

after annualizing the effectively connected taxable income for the

annualization period. Similar rules apply if the partnership uses

the adjusted seasonal installment method. See the instructions for

Parts II through IV.

If the partnership begins using the prior year safe harbor

method and it determines later in the tax year (based upon the

standard option annualization method described later in these

instructions) that it will not meet the 50% of ECTI requirement

described in the last bulleted item above, it may make all

subsequent installment payments using the standard option

annualization method and it will not be subject to the penalty

determined on Schedule A (Form 8804). This change in method

must be disclosed in a statement attached to the Form 8804 the
Form 8804-W (WORK SHEET) 2008 Page 5

Parts II Through IV

If only the adjusted seasonal installment method (Part II) is used,

complete Parts II and IV. If only the annualized income installment

method (Part III) is used, complete Parts III and IV. If both

methods are used, complete all three parts. Enter in each column

on line 10 the amounts from the corresponding column of line 42.

Do not figure any required installment until after the

end of the month preceding the due date for that

installment.

CAUTION

Line 11

Include on line 11 any 2007 overpayment that the partnership

chose to credit against its 2008 tax. The overpayment is credited

against unpaid required installments in the order in which the

installments are required to be paid.

Also include on line 11 any:

● Section 1446 tax paid or withheld by another partnership in

which the partnership filing this Form 8804-W was a partner

during the tax year. See the Instructions for Form 8804, line 6b, in

the Instructions for Forms 8804, 8805, and 8813.

● Section 1445(a) or 1445(e)(1) tax withheld from or paid by the

partnership filing this Form 8804-W during the tax year for a

disposition of a U.S. real property interest. See the instructions for

Form 8804, line 6c, in the Instructions for Forms 8804, 8805, and

8813

The partnership generally enters these amounts in the column

that corresponds to the installment period for which these

amounts were paid or withheld. However, if the partnership learns

about the payments or withholding in a subsequent installment

period, the partnership may claim them in that period.

Annualized income installment method and/or adjusted

seasonal installment method. If the partnership’s ECTI is

expected to vary during the year because, for example, it

operates its business on a seasonal basis, it may be able to lower

the amount of one or more required installments by using the

annualized income installment method and/or the adjusted

seasonal installment method. For example, a ski shop, which

receives most of its income during the winter months, may be

able to benefit from using one or both of these methods in figuring

one or more of its required installments.

Note. Part II does not reflect the lower preferential rates permitted

under Regulations section 1.1446-3(a)(2). This was done because,

for most taxpayers, the income reported in Part II will be

predominantly (or exclusively) ordinary income. If the partnership

wishes to consider lower preferential rates for Part II (and if the

requirements outlined in the Note in the line 30 instructions are

met), it must attach a schedule which appropriately expands lines

14 and 21 through 24 to show the applicable special types of

income or gain and the applicable percentages (see, for example,

lines 32 and 33 of this schedule).

Line 9—Installment Due Dates

Fiscal-year taxpayers: Enter the 15th day of the 4th, 6th, 9th,

and 12th months of the partnership’s tax year in columns (a)

through (d). If the regular due date falls on a Saturday, Sunday, or

legal holiday, enter the next business day.

Line 10

Calendar-year taxpayers: Enter 4-15-2008, 6-16-2008,

9-15-2008, and 12-15-2008, respectively, in columns (a) through

(d).

Enter 25% of line 8 in columns (a) through (d) unless the

partnership uses the annualized income installment method or the

adjusted seasonal installment method.

Line 8

Enter the smaller of line 6 or line 7. However, if, for any installment

payment, line 6 is smaller than line 7 and you enter that smaller

line 6 amount on line 8, you will not qualify for the prior year safe

harbor when determining any penalty due on Schedule A (Form

8804) (see the line 7 instructions on page 4). Therefore, in that

case, for any subsequent installment payment during the tax year,

do not use the line 7 amount.

If the partnership begins using the prior year safe harbor

method and switches to the current year safe harbor (because the

partnership does not qualify for the relief described in the

previous paragraph (i.e., using the standard option annualization

method) or the partnership chooses not to continue using it), in

order to avoid an underpayment penalty with respect to the

current installment payment, the partnership must pay the sum of

(a) the current installment payment based on the current year safe

harbor, plus (b) the sum of the amount by which the current year

safe harbor exceeds the prior year safe harbor amount paid in for

each prior installment period during which it qualified for the prior

year safe harbor.

partnership files for the current tax year and the statement must

include enough information to allow the IRS to determine whether

the change was appropriate.

To use one or both of these methods, complete Part II and/or

Part III of the form. If those Parts are used for any payment date,

those Parts must be used for all subsequent payment due dates.

To arrive at the amount of each required installment, Part IV

automatically selects the smallest of (a) the annualized income

installment (if applicable), (b) the adjusted seasonal installment (if

applicable), or (c) the current year safe harbor (increased by any

recapture of a reduction in a required installment under section

6655(e)(1)(B)).

Extraordinary items. Generally, under the annualized income

installment method, extraordinary items must be taken into

account after annualizing the effectively connected taxable

income for the annualization period. Similar rules apply in

determining effectively connected taxable income under the

adjusted seasonal installment method. An extraordinary item

includes:

● Any item identified in Regulations section

1.1502-76(b)(2)(ii)(C)(1), (2), (3), (4), (7), and (8);

● A section 481(a) adjustment; and

● Net gain or loss from the disposition of 25% or more of the fair

market value of the partnership’s business assets during the tax

year.

Part II—Adjusted Seasonal Installment Method

These extraordinary items must be accounted for in the

appropriate annualization period. However, a section 481(a)

adjustment (unless the partnership makes the alternative choice

under Regulations section 1.6655-2(f)(3)(ii)(C)) is treated as an

extraordinary item occurring on the first day of the tax year in

which the item is taken into account in determining effectively

connected taxable income.

For more information regarding extraordinary items, see

Regulations section 1.6655-2(f)(3)(ii) and the examples in

Regulations section 1.6655-2(f)(3)(vii). Also see Regulations

section 1.6655-3(d)(3).

De minimis rule. Extraordinary items identified above resulting

from a particular transaction that total less than $1 million (other

than a section 481(a) adjustment) may be annualized using the

general rules of Regulations section 1.6655-2(f), or, if the

partnership chooses, may be taken into account after annualizing

the effectively connected taxable income for the annualization

period.

Complete this part only if the partnership’s base period

percentage for any 6 consecutive months of the tax year equals or

exceeds 70%. Figure the base period percentage using the

6-month period in which the partnership normally receives the

largest part of its ECTI. The base period percentage for any period

of 6 consecutive months is the average of the three percentages

figured by dividing the ECTI for the corresponding

6-consecutive-month period in each of the 3 preceding tax years

by the ECTI for each of their respective tax years.

Example. An amusement park with a calendar year as its tax

year receives the largest part of its ECTI during a 6-month

period, May through October. To compute its base period
Form 8804-W (WORKSHEET) 2008 Page 6

Paperwork Reduction Act Notice. Your use of this form is

optional. It is provided to aid the partnership in determining its

tax liability.

The time needed to complete this form will vary depending on

individual circumstances. The estimated average time is:

Learning about the

law or the form

Preparing

Form Recordkeeping the form

8804-W, Part I 8 hr., 7 min. 47 min. 57 min.

8804-W, Part II 21 hr., 16 min. 6 min. 27 min.

8804-W, Part III 21 hr., 3 min. 27 min.

8804-W, Part IV 5 hr., 58 min. 12 min.

If you have comments concerning the accuracy of these time

estimates or suggestions for making this form simpler, we would

be happy to hear from you. You can write to the Internal

Revenue Service, Tax Products Coordinating Committee,

SE:W:CAR:MP:T:T:SP, 1111 Constitution Ave. NW, IR-6526,

Washington, DC 20224. Do not send the tax form to this office.

Instead, keep the form for your records.

You are not required to provide the information requested on

a form that is subject to the Paperwork Reduction Act unless the

form displays a valid OMB control number. Books or records

relating to a form or its instructions must be retained as long as

their contents may become material in the administration of any

Internal Revenue law. Generally, tax returns and return

information are confidential, as required by section 6103.

6 min.

Line 31—Annualization Amounts

Enter the annualization amounts for the option used on line 29.

For example, if the partnership elects Option 1, enter on line 31

the annualization amounts 6, 3, 1.71429, and 1.2, in columns (a)

through (d), respectively.

4 2.4 1.5 1.09091

6 3 1.71429 1.2

4 4 2 1.33333

Option 1

Option 2

Standard option

1st

Installment

2nd

Installment

3rd

Installment

4th

Installment

Part IV—Required Installments Under Part II and/or

Part III

Before completing line 37 in columns (b) through (d), complete

lines 38 through 42 in each of the preceding columns. For

example, complete lines 38 through 42 in column (a) before

completing line 37 in column (b).

Line 37

For each installment, enter the smaller of line 38 or line 41 on

line 42. Also enter the result on line 10.

Line 42—Required Installments

Enter the reduction amounts by reason of valid certificates

received from foreign partners under Regulations section

1.1446-6T. See Certification of Deductions and Losses in the

Instructions for Forms 8804, 8805, and 8813 for additional

information. Also see the last sentence of the instructions for

lines 1a, 1d, 1g, and 1j earlier for additional information.

Line 30—Foreign Partner’s Allocable Share of ECTI

Option 1

Option 2

Standard option

3 5 8 11

2 4 7 10

3 3 6 9

1st

Installment

2nd

Installment

3rd

Installment

4th

Installment

Enter on lines 30a through 30d the foreign partner’s allocable

share of ECTI for the months entered for each annualization

period in columns (a) through (d) on line 29. To determine the

foreign partner’s allocable share of ECTI, see Effectively

Connected Taxable Income in the Instructions for Forms 8804,

8805, and 8813.

Use Option 1 or Option 2 only if the partnership

elected to use one of these options by filing Form

8842, Election To Use Different Annualization

Periods for Corporate Estimated Tax, on or before

the due date of the first required installment payment. Once

made, the election is irrevocable for the particular tax year.

CAUTION

6 min.

Part III—Annualized Income Installment Method

Line 29—Annualization Periods

Enter in the space on line 29, columns (a) through (d),

respectively, the annualization periods that the partnership is

using, based on the options listed below. For example, if the

partnership elects Option 1, enter on line 29 the annualization

periods 2, 4, 7, and 10, in columns (a) through (d), respectively.

Line 22

Enter the reduction to the line 21c amount by reason of valid

certificates received from the foreign partner under Regulations

section 1.1446-6T. See Certification of Deductions and Losses in

the Instructions for Forms 8804, 8805, and 8813 for additional

information.

If the partnership has certain extraordinary items, special rules

apply. Do not include on line 14 the de minimus extraordinary

items that the partnership chooses to include on line 21b. See

Extraordinary items on page 5.

If the partnership has certain extraordinary items of $1 million or

more from a transaction, or a section 481(a) adjustment, special

rules apply. Include these amounts on line 21b for the

appropriate period. Also, include on line 21b the de minimis

extraordinary items that the partnership chooses to exclude from

line 14. See Extraordinary items on page 5.

If the partnership has certain extraordinary items, special rules

apply. Do not include on line 30a, 30b, 30c, or 30d the de

minimis extraordinary items that the partnership chooses to

include on line 32a, 32d, 32g, or 32j, respectively. See

Extraordinary items on page 5.

If the partnership has certain extraordinary items that total $1

million or more from a particular transaction, or a section 481(a)

adjustment, special rules apply. Include these amounts on line

32a, 32d, 32g, or 32j, depending upon the type of income

against which the item applies, for the appropriate period. Also

include on line 32a, 32d, 32g, or 32j the de minimis extraordinary

items that the partnership chooses to exclude from line 30a,

30b, 30c, or 30d, respectively. See Extraordinary items on 

page 5.

percentage for this 6-month period, the amusement park figures

its ECTI for each May–October period in 2005, 2006, and 2007.

It then divides the ECTI for each May–October period by the

total ECTI for that particular tax year. The resulting percentages

are 69% (.69) for May–October 2005, 74% (.74) for May–October

2006, and 67% (.67) for May–October 2007. Because the

average of 69%, 74%, and 67% is 70%, the base period

percentage for May through October 2008 is 70%. Therefore, the

amusement park qualifies for the adjusted seasonal installment

method.

Note. With respect to lines 30b through 30d, enter the specified

types of ECTI if (a) such partner would be entitled to use a

preferential rate on such income or gain (see Regulations section

1.1446-3(a)(2)) and (b) the partnership has sufficient

documentation to meet the requirements of Regulations section

1.1446-3(a)(2)(ii).

Line 14

Line 21b

Lines 32a, 32d, 32g, and 32j

Lines 32b, 32e, 32h, and 32k