Partnerships›Bipartisan Budget Act of 2015 (BBA)
Administrative Adjustment Request
1225 Publ 541 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
Rather than filing an amended return, a partnership that is subject to the centralized partnership audit regime must file an administrative adjustment request (AAR) to change the amount or treatment of one or more partnership-related items. If filing electronically, file Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR), with a Form 1065 or Form 1065-X, Amended Return or Administrative Adjustment Request (AAR).
AARs filed under the centralized partnership audit regime. Partnerships subject to the centralized partnership audit regime and filing an AAR that results in an imputed underpayment and any interest or penalties related to the imputed underpayment should report the imputed underpayment and any related interest and penalties on Form 1065 or 1065-X (as applicable). See the Instructions for Form 1065.
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Tax reform. Tax reform legislation impacting federal taxes, credits, and deductions was enacted in P.L. 119-21, commonly known as the One Big Beautiful Bill Act, on July 4, 2025. Go to IRS.gov/OBBB for more information and updates on how this legislation affects your taxes.
Preparing and filing your tax return. After receiving all your wage and earnings statements (Forms W-2, W-2G, 1099-R, 1099-MISC, 1099-NEC, etc.); unemployment compensation statements (by mail or in a digital format) or
See the instructions for Form 8082 or 1065-X (as applicable) for the following.
Information pertaining to certain modifications that are allowable for the partnership to include in its calculation of an AAR imputed underpayment.
Information pertaining to the ability for the partnership to make an election under section 6227(b)(2) to have the adjustments of the AAR taken into account by the reviewed year partners, rather than the partnership making an imputed underpayment.
Partner amended return filed as part of modification of the imputed underpayment during a BBA examina- tion. Section 6225(c) allows a BBA partnership under examination to request specific types of modifications of any imputed underpayment proposed by the IRS. One type of modification (under section 6225(c)(2)) that may be requested is when one or more (reviewed year) partners file amended returns for the tax years of the partners that include the end of the reviewed year of the BBA partnership under examination and for any tax year with respect to which tax attributes are affected. See the Instructions for Form 8980.
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