If you file Form 8082 as a notice of inconsistent treatment, complete a single copy of the form, attach it to your tax return, and file it when you file your original return.
Who files: partners, S corporation shareholders, estate and domestic trust beneficiaries, foreign trust owners and beneficiaries, REMIC residual interest holders, and PRs
Item 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.
Item E: is the partnership applying modifications to the IU? If “Yes,” attach Form 8980.
Part III: enter the Part II item number before each explanation. Show how the IU was calculated and how modifications were applied.
| Question | Answer |
|---|---|
| Form Name | Form 8082 |
| Form Length | 2 pages |
| Fillable? | Yes |
| Fillable fields | 68 |
| Avg. time to fill out | 12 min |
| Edition | October 2025 |
| Issuing agency | Department of the Treasury Internal Revenue Service |
| Matches the agency's file | Yes, checked October 2, 2026 |
| Other names | Form 8082, 8082, IRS Form 8082, Form 8082 instructions, Notice of Inconsistent Treatment, Administrative Adjustment Request |
| Official source | Form 8082 (Rev October 2025), Department of the Treasury Internal Revenue Service |
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