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2025›Partner’s Instructions for Schedule K-1 (Form 1065)›General Instructions

Inconsistent Treatment of Items

Instruction 1065 (Schedule K-1) — Partner's Instructions for Schedule K-1 (Form 1065), Partner's Shares of Income, Credits, Deductions, etc. · 2026-10-03 edition · updated 2026-10-04 · United States

If you’re a partner in a partnership that hasn’t elected out of the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (the BBA), you must report the items shown on your Schedule K-1 (and any attached statements) the same way that the partnership treated the items on its return.

If the treatment on your original or amended return is inconsistent with the partnership’s treatment, or if the partnership was required to file a return but hasn’t, you must file Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR), with your original or amended return to identify and explain any inconsistency (or to note that a partnership return hasn’t been filed).

If you’re required to file Form 8082 but don’t do so, you may be subject to the accuracy-related penalty. This penalty is in addition to any tax that results from making your amount or treatment of the item consistent with that shown on the partnership’s return. Any deficiency that results from making the amounts consistent may be assessed immediately.

Instructions for Schedule K-1 (Form 1065) (2025) Catalog Number 11396N Dec 17, 2025 Department of the Treasury Internal Revenue Service www.irs.gov

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▸Contents — Instruction 1065 (Schedule K-1) — Partner's Instructions for Schedule K-1 (Form 1065), Partner's Shares of Income, Credits, Deductions, etc.
Instruction 1065 (Schedule K-1) — Partner's Instructions for Schedule K-1 (Form 1065), Partner's Shares of Income, Credits, Deductions, etc.

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