Notice of Inconsistent Treatment or Administrative                                                                         OMB No. 1545-0074 
Form 8082                                            Adjustment Request (AAR) 
(Rev. October 2023)         (For use by partners, S corporation shareholders, estate and domestic trust beneficiaries, foreign 
Department of the Treasury  trust owners and beneficiaries, REMIC residual interest holders, TMPs, and PRs.)                                           Attachment   
Internal Revenue Service               Go to www.irs.gov/Form8082 for instructions and the latest information.                                         Sequence No. 84 
Name(s) shown on return                                                                                                      Identifying number 

Part I    General Information 
   1 Check boxes that apply.                                                                                                                               Yes  No 
     (a)    Notice of inconsistent treatment (go to line 2)
     (b)    AAR (choose one below—see instructions)
        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           5          Internal Revenue Service Center where pass-through entity filed its return

   4 Name, address, and ZIP code of pass-through entity              6          Tax year of pass-through entity 
                                                                                                                  /          /       to                /   / 
                                                                     7          Your tax year 
                                                                                                                  /          /       to                /   / 
Part II   Inconsistent or Administrative Adjustment Request (AAR) Items 
                                                     (b)  Inconsistency is in,    (c)  Amount as shown on  
                                                      or AAR is to correct      Schedule K-1, Schedule Q, or  
     (a)  Description of inconsistent or AAR items   (check boxes that apply)   similar statement; a foreign      (d)  Amount you are reporting (e)  Difference between 
                    (see instructions)                                          trust statement; or your return,                                         (c) and (d) 
                                                     Amount of  Treatment        whichever applies (see                                                    
                                                      item         of item             instructions) 

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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)