8082

Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)

Agency
IRS
Revision
Rev. October 2025
Fillable fields
59
Pages
2
Official source
IRS form page
Checked
October 21, 2026
Fill 8082 online
Page 1 of form 8082

Form 8082: Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)

Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR), has two uses. The form says it is for use by partners, S corporation shareholders, estate and domestic trust beneficiaries, foreign trust owners and beneficiaries, REMIC residual interest holders, and partnership representatives (PRs).

As a notice of inconsistent treatment, it tells the IRS that an item is being reported differently from the way a pass-through entity reported it on Schedule K-1, Schedule K-3, Form 8986, Schedule Q or a foreign trust statement, or that one of those statements was not received by the due date of the return. As a BBA AAR, it is filed by the PR, or by the designated individual (DI) when the PR is an entity, to request an administrative adjustment correcting a previously filed partnership return under the centralized partnership audit regime of the Bipartisan Budget Act of 2015 (BBA).

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What's on Form 8082

Name and identifying number

The name or names shown on the return and the identifying number.

Part I, line 1

Box (a) for a notice of inconsistent treatment, or box (b) for a BBA AAR, followed by items A through E about a PR change, an imputed underpayment (IU), the section 6227(b)(2) election, the PR's signature and modifications to the IU.

Lines 2 to 7

The type of pass-through entity (S corporation, estate, trust, REMIC or BBA partnership), its EIN, name and address, the IRS service center where it filed, its tax year, and your tax year.

Part II, lines 8 to 11

Up to four items, each with a description, whether the amount or the treatment is inconsistent or being corrected, the amount as shown on the statement or return, the amount being reported, and the change.

Part III: explanations

Page 2 holds the explanations, each starting with its Part II item number. The form says to show how the IU was calculated and how modifications were applied.

How to fill out Form 8082

  1. 1

    Line 1

    Check box (a) for a notice of inconsistent treatment and go to line 2. A BBA partnership filing an AAR checks box (b) and answers items A through E. The instructions say the PR manually signs under item D, and that Form 8979 is attached for a PR change and Form 8980 for IU modifications.

  2. 2

    Lines 2 to 7

    The instructions say this information can generally be found on Schedule K-1, Form 8986, Schedule Q or the foreign trust statement.

  3. 3

    Columns (a) and (b)

    In column (a), enter the line number and description shown on the statement received, or a full description if none was received. In column (b), check amount of item, treatment of item, or both. The instructions say columns (d) and (e) are skipped when only treatment is checked.

  4. 4

    Columns (c), (d) and (e)

    Column (c) is the amount on the statement received, or zero if no statement was received, the entity filed no return, or the item was omitted. Column (d) is the amount being reported as correct. Column (e) is the difference, with negative amounts in parentheses.

  5. 5

    Part III

    Explain how each item should be treated and why. The instructions give set wording for missing items, such as "Schedule K-1 (Schedule K-3, Schedule Q, and/or foreign trust statement) not received."

  6. 6

    Attach it

    For a notice of inconsistent treatment, complete a single copy, attach it to your tax return and file it with the original return. A BBA AAR goes with Form 1065, plus Forms 8985 and 8986 when they apply.

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How and when to file, and penalties

Not filed by itself

The instructions say "Don't file Form 8082 by itself." A notice of inconsistent treatment is attached to the tax return, and the instructions say a BBA AAR's Form 8082 should be attached as a PDF to Form 1065.

One form per entity

A separate form for each pass-through entity. Part II has four lines, so more than four monetary items from one entity need additional Forms 8082.

When an AAR can be filed

The instructions say generally within 3 years after the later of the date the entity's return was filed or its last filing day (excluding extensions). A BBA partnership that has received a notice of administrative proceeding may not file an AAR.

Without the notice

The instructions say that if the IRS is not notified of an inconsistent item, a deficiency from making it consistent with the entity's return may be assessed immediately.

Penalties

The instructions say disregarding the filing requirements may bring the accuracy-related penalty under section 6662 or the fraud penalty under section 6663.

Large refunds

An AAR requesting an electronically deposited refund of $1 million or more attaches Form 8302.

Related forms

Who fills out Form 8082?

  • Partners in a BBA partnership

    A partner reporting an item differently from a Schedule K-1 or Schedule K-3, or from a Form 8986 issued with a BBA AAR. The instructions say a partner may not use it to depart from finally determined adjustments after a BBA audit.

  • S corporation shareholders

    A shareholder whose return is not consistent with the S corporation's return. The instructions say a shareholder cannot use it to request an administrative adjustment and files an amended income tax return instead.

  • Estate, trust and foreign trust beneficiaries

    Beneficiaries of an estate or domestic trust, and owners or beneficiaries of a foreign trust, use it only as a notice of inconsistent treatment, according to the instructions.

  • REMIC residual interest holders

    A holder reporting differently from the Schedule Q received from the REMIC. The instructions exclude a holder whose REMIC had no more than one residual interest holder at any one time during the tax year.

  • Partnership representatives

    The PR, or the DI when the PR is an entity, files a BBA AAR on behalf of the partnership. The instructions say a partner may file an AAR for the partnership only in its capacity as the PR.

  • When it is not used

    The instructions list cases such as partners in a partnership that elected out of BBA under section 6221(b), amounts held back by the at-risk or passive activity rules, and a REMIC correcting its own return, which uses Form 1065-X.

Owners and beneficiaries of pass-through entities use it as a notice of inconsistent treatment. A BBA partnership's PR uses it to file an AAR.

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Questions about Form 8082

What is a notice of inconsistent treatment?

It tells the IRS that you are treating an item differently from the way the partnership, S corporation, estate, trust or REMIC reported it on your Schedule K-1, Schedule K-3, Form 8986, Schedule Q or foreign trust statement.

What if a Schedule K-1 never arrived?

The instructions say Form 8082 is also used when a Schedule K-1, Schedule Q or foreign trust statement was not received by the return's due date. Parts I and II are completed to the best of your knowledge.

Who files a BBA AAR on Form 8082?

The partnership representative, or the designated individual when the PR is an entity, on behalf of a BBA partnership correcting a previously filed partnership return.

Can an S corporation shareholder use Form 8082 to amend?

No. The instructions say a shareholder cannot use it to request an administrative adjustment to correct S corporation items and files an amended income tax return instead.

Can Form 8082 be mailed on its own?

No. The instructions say not to file it by itself. It goes with your tax return, or with Form 1065 for a BBA AAR.

How many items fit on one form?

Part II has four lines. The instructions say to use additional Forms 8082 for more than four monetary items, and a separate form for each pass-through entity.