General Instructions

Electronic Submission of Form 8980 Internal Revenue Code (IRC) section 6241(10), in part, gives the IRS authority to require electronic filing of anything required to be filed or submitted under section 6225(c). Please submit Form 8980, attachments, and related forms electronically. Refer to the BBA website (IRS.gov/bbaesubmit) for steps and instructions for electronic submission.

Note: Administrative Adjustment Requests (AARs), including AARs with an attached Form 8980, must be filed at the Internal Service Center location where the partnership’s original return was filed in the manner that the original return was filed (on paper or electronically submitted). Electronically filed AARs cannot be submitted in the BBA Online Form Submission Service (OFSS), but instead are e-filed through the Modernized e-file (MeF) system. For further information regarding the filing of BBA AARs, see the Instructions to Form 1065 and the BBA AAR page at irs.gov/bbaaar.

Be sure to download and complete the latest version of the fillable forms available from IRS.gov/forms-instructions . Any earlier version of the forms cannot be submitted electronically and will be rejected. Also, see “Important Tips for Electronic Submission” below.

If you are having difficulty downloading or opening the PDF form, it may be because of the browser you are using. Check that “Adobe” is set as the program that opens the PDF, by right clicking on any PDF file on your computer. Once you right click, select “properties.” If “Adobe” isn’t the program that the form “opens with”, change it to “Adobe”.

Important Tips for Electronic Submission for Partnerships Under Examination

• Download and complete the latest version of the fillable forms available from IRS.gov/forms-instructions. Any earlier version of the forms

cannot be submitted electronically and will be rejected.

• The fillable form has mandatory fields that must be completed in order for the form to be accepted when it is submitted. Mandatory fields

are generally outlined in red boxes on the fillable form. If you do not complete all mandatory fields on the fillable form, you will get a pop-up message stating that you have not completed all of the mandatory fields. Please note: ALL FORMS LISTED BELOW AS “PRIMARY” OR “RELATED” MUST BE SUBMITTED IN THEIR FILLABLE FORMAT, not printed and scanned to create a PDF file. The attachments, signature files, and “Manual signature” forms listed below may be printed and scanned to create a PDF or other type of document in order to upload for electronic submission.

• Name fields : Do not enter double blank spaces or punctuation.

• Taxpayer ID Number (TIN) fields :

• For TIN fields which can be either an Employer Identification Number (EIN) or Social Security Number (SSN), be sure to enter a dash when entering an EIN (Example: XX-XXXXXXX), and two dashes when entering an SSN (Example: XXX-XX-XXXX).

  • For fields that stipulate an EIN or SSN, you do not need to enter the dashes, as the fillable form will appropriately format the number

and automatically include the dash/dashes.

• U. S. Zip Code fields : U.S. Zip Code fields should be entered as either 5 or 9 numeric digits, no dashes. The fillable form will automatically

include a dash if 9 numeric digits are entered.

• Form 8980, Attachments to Form 8980, and Form 8980 related forms (Form 8982, Form 8983, and Form 15028):

  • Do not password protect or encrypt attachments.

  • The file name should be a unique, meaningful name and description. The following file name requirements must be followed when

naming files: Allowed :

• Alpha (A-Z);

• Numeric (0-9);

• Hyphen/dash (-);

• Underscore (_);

• Maximum of 50 characters (including the file extension);

• Allowed file extensions:.doc,.docx,.pdf,.xls,.xlsx,.zip;

• Use unique filenames. For example, you cannot have two attachments as follows: “form.pdf” and “form.doc” included in the same

submission.

• Avoid naming files; “Other”, “PDF Attachment”, “Miscellaneous Information”, or any other generic term.

Not Allowed:

• Blank spaces

• Consecutive dashes or underscores

• Special characters (other than non-consecutive dashes or underscores)

• When electronically submitting Form 8980 (Primary form) and any required Related Forms (Forms 8982, Forms 8983, and Form

15028), the following categories of forms and attachments are possible:

• Primary form: Form 8980

• Form 8980 Attachments (includes statements and schedules which provide further information to information requested in Form 8980)

• Related form: Form 8982

• Form 8982 Signature files (Each Form 8982 submitted must have an associated signature file that includes a scanned image of partner

signature page)

Publication 5346 (Rev. 12-2024) Catalog Number 72774P Department of the Treasury Internal Revenue Service www.irs.gov

• Form 8982 Attachments (includes statements and schedules when additional space is needed beyond form capacity)

• Related Form: Form 8983

• Form 8983 Signature files (Each Form 8983 submitted must have an associated signature file that includes a scanned image of partner

signature page)

• Form 8983 Attachments ( includes required statements and schedules as applicable and when additional space is needed beyond form

capacity)

• Related Form: Form 15028

• Form 15028 Attachments (when additional space is needed beyond form capacity)

• Other forms relating to the Modification process that can be submitted electronically as stand-alone forms:

• Form 8981

• Form 8984

• Form 15027 (agreement)

• Form 14726

• Modification-related Form Signature Requirements : Electronically submitted forms have different signature requirements depending on the

form. The following is a summary of the form signature methods and submission formats:

*Explanation of Signature Methods :

PIN signature = 5-digit PIN signature is transmitted as part of the form when the form is electronically submitted. This is the PIN that is self-selected during the Transmitter Control Code (TCC) application step of the multi-step process for electronic submission (go to IRS.gov/ bbaesubmit for the complete steps and instructions for electronic submission). A Power of Attorney (POA) for the Partnership Representative (PR) may sign on behalf of the PR using the POA’s PIN and information where the PR is unable to sign.

If you didn’t select a PIN or don’t remember the PIN selected, you must select or change the PIN before signing and submitting the form. The “typed” name of the person signing the form must exactly match the name entered during the TCC application step for electronic submission. For example, if the name entered during the TCC application step is John T. Smith, the typed name on the form must be John T. Smith, not John Smith, JT Smith, etc.

Manual signature – separate file = Requires a separate file to be uploaded (in addition to the completed fillable form) that includes the signature page with the scanned image of the signature, referred to as a “signature file”.

Manual signature – no separate file = The form is completed, manually signed, and then scanned to create a PDF file to upload for electronic submission.

• Successful Electronic Submission = Receipt ID: When you have successfully submitted your forms electronically, a “Receipt ID Number”

will be displayed along with a list of forms that have been submitted. You should print and keep the Receipt ID page displayed. You need the Receipt ID in order to check the status of your form submission. If the submission was “Rejected”, you will receive the reason(s) for the rejection so that you can fix the forms and resubmit them. If the status is “Accepted”, there is nothing further you need to do. Before the expiration of your submission deadline, a submission must be in “accepted status” in order to have met that deadline.

Purpose of Form 8980 Section references are to the Internal Revenue Code (IRC) unless otherwise noted.

Form 8980 is submitted by a partnership to request the modification of an imputed underpayment under section 6225(c). An imputed underpayment is reported to a partnership in a notice of proposed partnership adjustment (NOPPA). Additionally, Form 8980 is also used by a partnership that is applying certain permitted modifications to an imputed underpayment included in the filing of an Administrative Adjustment Request (AAR). In the case of an AAR that includes modifications to an imputed underpayment, the partnership should complete and attach Form 8980 (including all required Form 8980 supporting forms and attachments, and any supporting documents) to the AAR when filed. Note: AARs that include Form 8980 must be filed at the Internal Revenue Service Center location where the partnership’s original return was filed.

Modification Request Not for Disputed Partnership Issues . A request for modification is a request to modify an imputed underpayment and is not a request to appeal or modify partnership adjustments. The Office of Appeals handles formal protests of any proposed partnership adjustments and imputed underpayment computations when requested prior to the issuance of the NOPPA. For further information on the Appeals process and filing a formal protest prior to receiving a NOPPA, see Publication 5, Your Appeal Rights and How To Prepare a Protest If You Don’t Agree.

Who Must Submit Modification Request of a NOPPA Imputed Underpayment . A partnership choosing to request modification of a proposed imputed underpayment reported in a NOPPA should use Form 8980 to request the modification. The partnership representative (PR) should complete and sign Form 8980 and include all required Form 8980 supporting forms and attachments and any supporting documents when Form 8980 is submitted. The IRS will acknowledge your request and will contact you if additional information is required in order to evaluate your request and make a determination.

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Modification of Adjustments That Do Not Result in an Imputed Underpayment . If the imputed underpayment calculation in the NOPPA results in an amount that is zero or less than zero, or if there are net negative adjustments that are excluded from the calculation of the imputed underpayment, modification may be requested with respect to the underlying adjustments under the following types of modification and using the appropriate Part of Item E of Form 8980:

• Partner modification amended returns (PMARs) (use Part I);

• Partner alternative procedure (PAP) (use Part I);

• Modification of the number and composition of the imputed underpayments (use Part V);

• Closing agreements (use Part VII for partner closing agreements, and use Part IX for a source partnership closing agreement); or

  • Other Modifications, if applicable (use Part IX).

Modifications Applied to an Imputed Underpayment Reported in an Administrative Adjustment Request (AAR) . Form 8980 is also used to report to the IRS any permitted modifications that are being applied to an imputed underpayment reported in an AAR. The PR should complete and sign Form 8980, including all required Form 8980 supporting forms and attachments and any supporting documents, and include it with the AAR when filed. AARs must be filed at the IRS Service Center where the partnership’s original return was filed, in the manner that the original return was filed (on paper or electronically submitted).

One Form 8980 Per Reviewed Year : If a partnership is requesting modification for more than one reviewed year, a Form 8980 should be completed and submitted for each reviewed year. Each Form 8980 pertains to a particular partnership and a particular reviewed year.

Partnership Responsibility to Provide Information to Partners . The failure of the partnership to provide all necessary information to the partner in order for the partner to fulfill its requirements pertaining to a particular requested modification may result in the IRS’s denial, in whole or in part, of the partnership’s request for modification. For all modification requests involving one or more relevant partners’ actions affecting the source partnership’s modification request, the PR must provide to each relevant partner their distributive share of all proposed partnership adjustments set forth in the partnership’s NOPPA, regardless of whether such adjustments resulted in an imputed underpayment(s). This information must also be provided by the PR on Form 8980, Item C, Allocation of Adjustments Relevant to Modification. The PR should provide all necessary information with regard to each adjustment allocation in order for the partner to fulfill the requirements pertaining to a particular requested modification. Such information includes a description of each positive and negative adjustment, grouping, subgrouping, and whether or not the adjustment was included in the general or a specific imputed underpayment.

When to Submit Modification Request of a NOPPA Imputed Underpayment and Adjustments That Do Not Result in an Imputed Underpayment . Under section 6225(c)(7), a partnership has 270 calendar days from the date the NOPPA is mailed to request modification. Form 8980, along with all required supporting forms and attachments should be submitted within this 270-day modification submission period. This period may be extended if it is requested by the partnership and approved by the IRS. See “Extension of the Modification Submission Period” below.

Modifications to an Imputed Underpayment Included in an Administrative Adjustment Request (AAR) . If filing an AAR with modifications, refer to the instructions in the relevant AAR forms regarding the allowable time period to file an AAR. Form 8980, including all required attachments and supporting documentation, should be attached to an AAR when it is filed if such AAR includes any permitted modifications that are being applied to the imputed underpayment reported in the AAR. Permitted modifications to an imputed underpayment in an AAR include: modifications regarding tax-exempt partners; the applicable highest tax rate; certain passive activity losses of specified partners or qualified relevant partners of publicly traded partnerships; the limitation or restriction in the grouping of adjustments; qualified investment entity partners; foreign partner tax treaty modification and statutory exemptions; and other modifications (if appropriate). Modifications for partner amended returns, partner alternative procedure, and closing agreements are not permitted in an AAR. AARs must be filed at the Internal Service Center location where the partnership’s original return was filed in the manner that the original return was filed (on paper or electronically submitted). If a modification is requested but the Form 8980 is not attached to the AAR, the modification is denied. See also irs.gov/bbaaar for additional information.

Extension of the Modification Submission Period . If the partnership’s 270-day period from the NOPPA mailing date has not expired and the partnership needs additional time to submit a modification request, to fully complete a timely submitted Form 8980 modification request, to provide the required supporting documents relative to a modification request, or to correct a previously submitted modification request, the 270-day period under section 6225(c)(7) may be extended, if it is requested by the partnership and approved by the IRS. Use Form 8984, Extension of the Taxpayer Modification Submission Period Under Section 6225(c)(7), to request an extension of the 270-day modification submission period. Such request, if made, must be submitted and approved prior to the expiration of the 270-day period. Form 8984 should be submitted electronically. See IRS.gov/ bbaesubmit.

What to Submit with Form 8980 All related forms (when required) such as Forms 8982, 8983, and 15028, and any required attachments to Form 8980 should be submitted along with Form 8980. The related forms and required supporting attachments will depend upon the type(s) of modifications being requested, or in the case of an AAR, the permitted modifications being applied to the imputed underpayment in the AAR. See the specific instructions for each type of modification requested for the required related forms and supporting attachments that needs to be included with Form 8980 when submitted.

Who Must Sign The partnership representative (PR) of the source partnership requesting modification, or applying permitted modifications in the case of an AAR, must sign Form 8980, Item F. For further information, see “Modification-related Form Signature Requirements, *Explanation of signature Methods” above, under “Important Tips for Electronic Submission.”

Where to Submit Submitting Form 8980 pursuant to receipt of a NOPPA. You must upload the completed fillable version of the form. (Do not print, scan, and upload Form 8980). See “Electronic Submission of Form 8980” at the beginning of these instructions, for additional information.

Submitting Form 8980 with an AAR. You should attach the completed form with the AAR being filed. AARs must be filed at the IRS Service Center where the partnership’s original return was filed. Refer to the instructions in the relevant AAR forms.

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BBA Partner Payments Related to Requested Modifications All partner payments relating to modifications that will be requested must be properly identified as a partner payment under BBA modification. IRS offers several payment options. Partners can pay online or by phone, mobile device, cash (maximum $1,000 per day and per transaction), check, or money order. Go to IRS.gov/Payments for payment options. However partners choose to pay, they must identify their payment by selecting “ Partner Payment (Pymnt) for BBA Modification ”. If partners choose to mail a tax payment, they must make their check or money order payable to “United States Treasury” for the full amount due. On their payment, they must put their name, current address, daytime phone number, and SSN/TIN. If they are a joint filer, enter the SSN shown first on their return. Also, include the tax year and description as follows: “Modification [Insert Tax Year] Form [Insert Form Number]”. To help process the payment, enter the amount on the right side of the check like this: $XXX.XX. Do not use dashes or lines (for example, do not enter “$XXX-“ or “$XXXxx100”) .

Waiver of the Modification Submission Period If the partnership has submitted a complete and accurate Form 8980 along with all required attachments and supporting documentation and does not need the full 270-day period (or longer period if an extension was previously approved) to submit supplemental modification requests or provide additional information, the partnership may request to waive the remainder of the modification submission period by submitting Form 8981, Waiver of the Period Under IRC Section 6231(b)(2)(A) and Expiration of the Period for Modification Submissions Under IRC Section 6225(c)(7) . If the IRS approves the waiver, you will be notified in writing. An approved Form 8981 may allow the IRS to complete its evaluation of the partnership’s modification request, notify the partnership of the modification acceptance or denial, and issue the notice of final partnership adjustment (FPA) earlier than if a waiver is not requested. Form 8981 should be submitted electronically.

Substantiation of Facts Supporting a Modification Request A partnership requesting modification must demonstrate to the satisfaction of the IRS that any modification requested is appropriate and accurate. The partnership bears the burden of providing all documents required to establish the appropriateness and accuracy of a modification request. The IRS may deny modification, in whole or in part, if the partnership fails to provide sufficient evidence of the appropriateness and accuracy of a modification request.

Notification of Modification Acceptance or Denial . All modification requests pursuant to a NOPPA must be approved by the IRS. The IRS will notify the partnership in writing of the modification determination.

Appeal of Modification Determination . Regarding modification requests pursuant to a NOPPA, once the partnership is notified, in writing, regarding the details of approved, partially approved, and denied modifications, along with the computation of the resulting modified imputed underpayment(s), if the partnership disagrees with the IRS’ determination, the partnership may first request a conference with the group manager. If there is still disagreement after the conference, the partnership can appeal its case to the IRS Independent Office of Appeals. The modification determination notification letter (Letter 5975) will provide information regarding what to do if you disagree with the determination.

Imputed Underpayment is a Liability of the Partnership Any imputed underpayment (after all approved modifications have been applied to the imputed underpayment) remains a liability of the partnership, unless the partnership makes a valid election under section 6226 to push out partnership adjustments and the applicability of any penalties, additions to tax, or additional amounts to its partners from the reviewed year as an alternative to payment of the imputed underpayment. The election under section 6226 may only be made after the FPA is mailed to the partnership, and must be submitted within 45 days of the date the FPA is mailed by the IRS.

Definitions 270-Day Modification Submission Period Expiration Date refers to the end of the period defined in section 6225(c)(7) during which an audited partnership may request modification (including the submission of all required supporting documents). This period is 270 calendar days from the date the NOPPA is mailed. The 270-Day Modification Submission Period Expiration Date is included on the top right section of the NOPPA Letter 5892/5892-A received by the partnership/partnership representative. The submission period may be extended if requested by the partnership (using Form 8984) and approved by the IRS.

Adjustment year means the partnership taxable year in which:

(i) In the case of an adjustment pursuant to the decision of a court in a proceeding brought under section 6234, such decision becomes final; (ii) In the case of an administrative adjustment request (AAR) under section 6227, such AAR is filed; or (iii) In any other case, an FPA is mailed under section 6231 or, if the partnership waives the restrictions under section 6232(b) (regarding limitations on assessments), the waiver is executed by the IRS.

Adjustment year partner means any person who held an interest in a partnership at any time during the adjustment year.

Adjustments That Do Not Result in an Imputed Underpayment (ATDNR) occur if: (i) After grouping, subgrouping, and netting the adjustments, the result of netting with respect to any grouping or subgrouping that includes a particular partnership adjustment is a net negative adjustment; or (ii) the imputed underpayment calculation results in an amount that is zero or less than zero. Any adjustment that does not result in an imputed underpayment is taken into account by the partnership in the adjustment year, except if an AAR is being filed. Modification may be requested with respect to such adjustments under the following types of modification: Amended returns, Alternative procedure, Number and composition of the imputed underpayments, Closing agreements, or, if applicable Other Modifications. Use the appropriate Part of Form 8980, Item E, to request such modification.

Closing Agreement for this purpose is an agreement entered into by the IRS and the partnership or any relevant partner, or both, if appropriate, pursuant to section 7121. See Form 8980, Item E, Part VII and the associated specific line instructions.

Direct partner means any person that holds a direct interest in a partnership, and not through another entity. A direct partner can also be a relevant partner.

First affected year is the taxable year of the partner that includes the end of the partnership’s reviewed year.

General Imputed Underpayment is calculated based on all adjustments (other than adjustments that do not result in an imputed underpayment) that are not taken into account to determine a specific imputed underpayment. If there is only one imputed underpayment in an administrative proceeding, it is a general imputed underpayment.

Grouping means placing partnership adjustments into one of four groupings: reallocation, residual, creditable expenditure, and credit. For partnerships under examination (and prior to any requested and approved modifications), the grouping of each proposed partnership adjustment is shown on the Form 14792 received by the partnership.

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Imputed Underpayment is an amount determined, in accordance with sections 6225, 6226, 6227 and the Regulations thereunder.

Indirect partner means any person who has an interest in a partnership through their interest in one or more pass-through partners or through a whollyowned entity disregarded as separate from its owner for federal tax purposes. An indirect partner can also be a relevant partner.

Modification refers to the process of the source partnership requesting and obtaining modification to a proposed imputed underpayment, or partnership adjustment that that does not result in an imputed underpayment, set forth in a NOPPA pursuant to the provisions in section 6225(c) and applicable Regulations. Modification for an AAR refers to the partnership applying certain permitted modifications to an imputed underpayment pursuant to applicable Regulations.

Modification year is any taxable year with respect to which any tax attribute of the relevant partner is affected by reason of taking into account the relevant partner’s distributive share of all partnership adjustments in the first affected year. A modification year may be a taxable year before or after the first affected year, depending on the effect on the relevant partner’s tax attributes from taking into account the relevant partner’s distributive share of the partnership adjustments in the first affected year. See Form 8982 and instructions for more information.

Netting means summing all adjustments together within each grouping or subgrouping, as appropriate, per Treas. Reg. section 301.6225-1(e).

Notice of Proposed Partnership Adjustment (NOPPA) is a notice of proposed partnership adjustment under section 6231(a)(2), and includes Letters 5892, 5892-A and Form 14792, Partnership Examination Changes, Imputed Underpayment Computation and Partnership Level Determinations as to Penalties, Additions to Tax and Additional Amounts .

Partner Alternative Procedure (PAP) refers to the procedure under section 6225(c)(2)(B) whereby a relevant partner fulfills all of the requirements under section 6225(c)(2), except that the partner does not file an amended return. If this modification is requested by the partnership, Form 8982 is a required related form to Form 8980. Therefore, in addition to meeting the requirements of the PAP, the partner must also complete and sign Form 8982 and provide it to the PR. The PR must submit Form 8982 (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part I and the associated specific line instructions, along with Form 8982 and instructions.

Partner Modification Amended Return (PMAR) is an amended return filed by a relevant partner of a source partnership and takes into account all of the partnership adjustments properly allocable to such partner. A PMAR includes a partner modification amended return for the partner’s first affected year, and all modification years. In order to meet the requirement under section 6225(c)(2), the PMARs filed by a partner must include the payment of all tax, penalties, additions to tax, and interest due as a result of taking into account all partnership adjustments properly allocated to the partner. If this modification is requested by the partnership, Form 8982 is a required related form to Form 8980. Therefore, in addition to filing the PMAR, the partner must also complete and sign Form 8982 and provide it to the PR. The PR must submit Form 8982 (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part I and the associated specific line instructions, along with Form 8982 and instructions.

Partnership adjustment means any adjustment to a partnership-related item as defined in applicable Regulations and includes any portion of a partnership adjustment.

Partnership-partner means a partnership that holds an interest in another partnership.

Pass-through partner means a pass-through entity that holds an interest in a partnership. A pass-through entity is:

• A partnership required to file a return under section 6031(a);

• An S corporation;

• A trust (other than a wholly-owned trust disregarded as separate from its owner for federal tax purposes); and

• A decedent’s estate.

For this purpose, a pass-through entity is not a wholly-owned entity disregarded as separate from its owner for federal tax purposes.

Publicly Traded Partnership is defined in section 469(k)(2) and means any partnership if -- interests in such partnership are traded on an established securities market, or interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof). A publicly traded partnership may request modification under IRC section 6225(c)(5) regarding specified passive activity losses of specified partners and qualified relevant partners pertaining to the publicly traded partnership’s activity. If such modification is requested by the partnership, Form 15028 must be completed and signed by the PR of the partnership and submitted (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part IV and the associated specific line instructions, along with Form 15028 and instructions.

Qualified Investment Entity is an entity defined under section 860(b), which includes both a regulated investment company (RIC) and a real estate investment trust (REIT). See Form 8980, Item E, Part VI and the associated specific line instructions.

Qualified Relevant Partner means a relevant partner that meets the requirements to be a specified partner, for each year beginning with the first affected year through the most recent year for which the publicly traded partnership has filed a return under section 6031. An indirect partner of the publicly traded partnership, if it meets the requirements of a qualified relevant partner, except for being a direct partner of the publicly traded partnership requesting modification, may also be a qualified relevant partner.

Relevant partner means any person for whom modification is requested by the source partnership that is:

• A reviewed year partner, including any pass-through partner, except for any reviewed year partner that is a wholly-owned entity disregarded as

separate from its owner for federal tax purposes; or

• An indirect partner except for any indirect partner that is a wholly-owned entity disregarded as separate from its owner for federal tax purposes.

Reviewed year means the partnership’s taxable year to which a partnership adjustment relates.

Reviewed year partner means any person who held an interest in the partnership at any time during the reviewed year.

Source partnership means the partnership under examination that is requesting modification of an imputed underpayment under section 6225(c), or a partnership filing an AAR to report an imputed underpayment for which it is applying permitted modifications to such imputed underpayment.

Specific Imputed Underpayment may be designated by the IRS, with respect to adjustments to a partnership-related item or items that were allocated to one partner or a group of partners that had the same or similar characteristics or that participated in the same or similar transaction or on such other bases as the IRS determines properly reflects the facts and circumstances. The IRS may designate more than one specific imputed underpayment with respect to any partnership taxable year. In addition, a partnership may request one or more specific imputed underpayments, as a modification. See Form 8980, Item E, Part V and the associated specific line instructions for more information.

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Specified Partner is a person that, for each taxable year beginning with the first affected year through the person’s taxable year in which or with which the partnership adjustment year ends, satisfies the following three requirements:

(A) The person is a partner of the publicly traded partnership requesting modification; (B) The person is an individual, estate, trust, closely held C corporation, or personal service corporation; and (C) The person has a specified passive activity loss with respect to the publicly traded partnership.

Specified Passive Activity Loss means, with respect to any specified partner or qualified relevant partner of a publicly traded partnership, the carryover amount, which is the lesser of the section 469(k) passive activity loss of that partner that is separately determined with respect to such partnership:

(A) At the end of the first affected year (affected year loss); or (B) At the end of:

(1) The specified partner’s taxable year in which or with which the adjustment year of the partnership ends, reduced to the extent any such

partner has utilized any portion of its affected year loss to offset income or gain relating to the ownership or disposition of its interest in such publicly traded partnership during either the adjustment year or any other year; or (2) If the adjustment year has not yet been determined, the most recent year for which the publicly traded partnership has filed a return under

section 6031.

Subgrouping means to place adjustments in further groupings if any partnership adjustment within any grouping is a negative adjustment. In general, an adjustment is subgrouped according to how the adjustment would be required to be taken into account separately under section 702(a) or any other provision of the IRC or regulation applicable to the adjusted item. For purposes of creating subgroupings, if any adjustment could be subject to any preference, limitation, or restrictions under the IRC (or not allowed in whole or in part against ordinary income) if taken into account by any person, the adjustment is placed in a separate subgrouping from all other adjustments within the grouping. For partnerships under examination (and prior to any requested and approved modifications), the subgrouping of each proposed partnership adjustment is shown on Form 14792 received by the partnership.

Tax attribute is anything that can affect the amount or timing of a partnership-related item, which can affect the amount of tax due in any taxable year. Examples of tax attributes include, but are not limited to, basis and holding period, as well as the character of items of income, gain, loss, deduction, or credit and carryovers and carrybacks of such items. Regarding a relevant partner’s tax attributes affected by reason of taking into account its distributive share of all partnership adjustments in the partner’s first affected year, see Form 8982 and instructions for more information.

Tax-Exempt Partner (for purposes of the modification of a partnership’s imputed underpayment under section 6225(c)(3)) is defined as a relevant partner which is a tax-exempt entity under section 168(h)(2)(A), (C), and (D). If this modification is requested by the partnership, Form 8983 is a required related form to Form 8980. Therefore, the tax-exempt partner must complete and sign Form 8983 and provide it to the PR, unless the partner is a foreign partner exempt from tax under a provision other than section 501(a). The PR must submit Form 8983 (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part II and the associated specific line instructions, along with Form 8983 and instructions.

Zero Adjustment/Zero Amount Adjustment is a partnership adjustment that is treated as zero, solely for purposes of the imputed underpayment calculation. Generally, if the effect of one partnership adjustment is reflected in one or more other partnership adjustments, the IRS may treat the one adjustment as zero solely for purposes of calculating the imputed underpayment. In addition, if a positive adjustment to an item is related to, or results from, a positive adjustment to another item, one of the positive adjustments will generally be treated as zero solely for purposes of calculating any imputed underpayment, unless the IRS determines that an adjustment should not be treated as zero in the calculation of the imputed underpayment. This also applies to the calculation of any imputed underpayment, including imputed underpayments calculated by a partnership or pass-through partner (for example, as part of the filing of an AAR under section 6227). Note: Adjustments treated as zero solely for purposes of the imputed underpayment calculation may not be excluded from the modification request.