Administrative Adjustment Request (AAR)

A partnership that is subject to the BBA centralized partnership audit regime must file an AAR to request an administrative adjustment in the amount or other treatment of one or more partnership-related items.

A BBA partnership filing an AAR shouldn’t file an amended tax return or amended Schedules K-1 and/or K-3. For an exception where a BBA partnership is itself a partner in a BBA partnership and is filing an amended return, see Partner amended return filed as part of modification of the IU during a BBA examination , later.

Electronically filed AARs. If the AAR will be filed electronically, complete Form 1065 with the corrected amounts and check box G(5). In addition, complete Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR). See the Instructions for Form 8082 for detailed instructions. For AARs filed on paper, see Paper-filed amended returns and AARs, later.

AARs for which payment is made. A partnership that hasn’t made a valid election out of the BBA centralized partnership audit regime, which is filing an AAR and that doesn’t elect to have its partners take adjustments into account, and that has adjustments that result in an imputed underpayment (IU), should report the IU and any interest and penalties on Form 1065, page 1, line 26. See the Instructions for Form 8082 for information on how to figure a BBA IU and what to do when an adjustment requested by an AAR doesn’t result in an IU. Also see IU Under the Centralized Partnership Audit Regime in the Instructions for Form 8082 for the required schedule to be included with Form 1065 that details the IU, prepaid interest, and prepaid penalties. See section 6233 for information about interest and penalties on the IU. Include the following information on your payment.

• Name of partnership.

• Form 1065.

• Taxpayer identification number (TIN).

• Tax year.

• BBA AAR Imputed Underpayment.

• Checks must be made payable to “United States Treasury.”

Mail payment to:

Internal Revenue Service Ogden Service Center Ogden, UT 84201-0011

Payments can be made by check or electronically. If making an electronic payment, choose the payment description “BBA AAR Imputed Underpayment” from the list of payment types.

If the partnership has an IU, the partnership may elect to have its partners take the adjustments into account instead of paying the IU. See the Instructions for Form 8082 for information on how to make the election.