Notice of Inconsistent Treatment or Administrative                                                                      OMB No. 1545-0074 
Form  8082                                            Adjustment Request (AAR) 
(Rev. December 2018)        (For use by partners, S corporation shareholders, estate and domestic trust beneficiaries, foreign                          Attachment   
Department of the Treasury      trust owners and beneficiaries, REMIC residual interest holders, TMPs, and PRs.)                                        Sequence No.  84 
Internal Revenue Service                ▶ Go to www.irs.gov/Form8082 for instructions and the latest information. 
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 Question A below

          A  Is  the  partnership  revoking  the  immediately  preceding  partnership  representative  (and/or  designated
             individual, if applicable) and appointing a successor (including the 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 for the reviewed year? If “Yes,” go to 
             Question C. If “No,” go to Question D  .              .   . .       .      . . .       . . .     .    .      . .   . .  . . .       .      . .
          C  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 Question D. If “No,” go to Question E .                               .  . . .       .      . .
          D  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 imputed underpayment? 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  
        (a)  Description of inconsistent or               or AAR is to correct   Schedule K-1, Schedule Q, or      (d)  Amount you are reporting (e)  Difference between 
      administrative adjustment request (AAR) items   (check boxes that apply)   similar statement, a foreign                                             (c) and (d) 
                     (see instructions)               Amount of  Treatment       trust statement, or your return,                                              
                                                          item      of item        whichever applies  (see 
                                                                                          instructions)                                                 

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For Paperwork Reduction Act Notice, see separate instructions.                                      Cat. No. 49975G                              Form  8082  (Rev. 12-2018) 

Form 8082 (Rev. 12-2018)                                                                               Page  2 
Part III Explanations—Enter the Part II item number before each explanation. If more space is needed,  
         continue your explanations on the back. Also, show how the imputed underpayment was calculated 
         and how modifications were applied.

                                            Form  8082  (Rev. 12-2018)