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apply to the imputed underpayment, the

Schedule K-1, Schedule Q, or foreign trust

Lines 2 through 6. Generally, the

imputed underpayment will be figured

statement you received, or you have not

information for these lines can be found on

using the highest rate in effect under

received a Schedule K-1, Schedule Q, or

Schedule K-1, Schedule Q, or foreign trust

section 1 or 11 for the tax year to which

foreign trust statement by the time you are

statement.

the adjustment relates. Write “BBA

required to file your tax return (including

Part II

Imputed Underpayment” in the bottom

extensions).

margin of page 1 of Form 1065 and

Check box (b) if you are filing an AAR

Column (a). If you received a

include the imputed underpayment and

on which you are requesting a change in

Schedule K-1, Schedule Q, or foreign trust

any interest or penalties related to the

the amount or treatment of any item from

statement, enter the line number and

imputed underpayment.

the way you reported it on your return as

description shown on the form. Otherwise,

If the partnership adjustment did not

originally filed or as you later amended it.

enter a complete description of the item.

result in an imputed underpayment or if

Column (b). If you believe that the

Note. The AAR can be used to file an

the partnership elects to have its partners

amount of any item shown on

early election into the new centralized

take the adjustments into account instead

Schedule K-1, Schedule Q, or foreign trust

partnership audit regime.

of paying the imputed underpayment, see

statement was not properly reported,

section 6226 (as amended by BBA) (but

Check both boxes if a partner or

check “Amount of item.”

without regard to subsection (c)(2)(C)

residual interest holder is reporting an item

If you believe that the treatment of any

thereof) for information on how the

on his or her AAR differently from the way

adjustment is taken into account. If the

item was not properly reported (such as a

that the item was reported on his or her

partnership elects to have the partners

long-term capital loss that a partner thinks

original return and inconsistently with the

take the adjustments into account, the

should be an ordinary loss), check

way the pass-through entity reported the

partnership will be required to furnish to

“Treatment of item.”

item.

each partner of the partnership for the tax

Check both parts of column (b) if either

Partnerships requesting substituted

year of BBA AAR, and file with the AAR, a

1 or 2 below applies:

return treatment.

statement of the partner's share of any

1. You believe that both the amount

adjustment to income, gain, loss,

Note. If you are a TMP filing an AAR on

and treatment of the item shown on

deduction, or credit indicated by the AAR.

behalf of the partnership and requesting

Schedule K-1, Schedule Q, or foreign trust

See section 6226(b) (as amended by

substituted return treatment, attach a

statement were not properly reported, or

BBA) for information on how the

statement to Form 8082 indicating that

you believe an item was omitted from the

adjustments are taken into account by the

you are requesting substituted return

form; or

partners. The words “Statement required

treatment.

2. The pass-through entity did not file

to be furnished by a partnership electing

A substituted return is an amended

a return or give you a Schedule K-1,

the alternative to payment of an imputed

return in which the TMP requests that the

Schedule Q, or foreign trust statement.

underpayment” should be written at the

treatment of an item shown on the AAR be

top of each statement.

Note. If you check only “Treatment of

substituted for the treatment of the item on

The statement must also include the

item,” you do not need to complete

the pass-through entity's return. If the IRS

following.

columns (d) and (e).

allows substituted return treatment, the

Name, correct TIN, and address of the

changes shown on the amended return

Column (c). If you attach Form 8082 to

partnership.

will be treated as corrections of

your original return, enter the amount as

Name and correct TIN of the partner.

mathematical or clerical errors, and the

Current or last address of the partner

shown on the Schedule K-1, Schedule Q,

IRS may credit or refund any overpayment

or foreign trust statement you received.

that is known to the partnership.

of tax to the partners or residual interest

The partner’s share of the items being

If you attach Form 8082 to your

holders based on the amended return or

adjusted as originally reported to the

amended return, enter the amount as

assess any resulting tax without a

partner.

shown on your original return or as you

deficiency or entity level proceeding.

Date the statement is furnished to the

amended it prior to the current

If the request is not treated as a

partner.

amendment.

substituted return, the IRS may credit or

The partnership tax year to which the

If the pass-through entity did not file a

refund any overpayment of tax to the

adjustments relate.

return, or if you did not receive a schedule

partners or residual interest holders per

or statement, or if you are reporting items

Specific Instructions

the request; conduct an examination of the

that you believe were omitted, enter zero

pass-through entity's return; or take no

Specific instructions for most of the lines

in column (c).

action on the request. When a request is

have been provided. Lines that are not

not treated as a substituted return, the IRS

Part III

explained are self-explanatory. If, after

cannot assess tax without a deficiency or

reading the instructions, you are unable to

Explain in detail the reasons you are

entity level proceeding.

complete an item in Part I or Part II, enter

reporting an inconsistent or amended item

In either case, if you are a TMP filing an

“See Part III” in the entry space for that

as follows.

AAR electronically, file an amended Form

item and provide the information there.

If you believe that the amount or

1065, but do not enter any amounts on the

treatment of any item shown on

form itself. Attach Form 8082 and identify

Note. If the pass-through entity did not file

Schedule K-1, Schedule Q, or foreign trust

the amount and treatment of any item you

a return or give you a Schedule K-1,

statement was not properly reported, state

are changing from the way it was reported

Schedule Q, or foreign trust statement by

how you think the item should be treated

on the original return. The TMP must sign

the time you are required to file your

and why.

the amended return.

return, complete Parts I and II to the best

If the pass-through entity has not filed a

of your knowledge.

Attach amended Schedules K-1

tax return by the time you are required to

showing the corrected amounts for each

file your tax return, enter as the

Part I

partner.

explanation, “Partnership (S corporation,

Line 1. Check box (a) if you believe an

Estate, Trust, or REMIC) return not filed.”

item was not properly reported on the

Instructions for Form 8082

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Instructions For Form 8082 - Notice Of Inconsistent Treatment Or Administrative Adjustment Request (Aar) Page 4

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