Form 8894 (Rev. 9-2017)
The revocation made with this form is available only for
partnership tax years beginning before January 1, 2018 and for
tax years in which no election under Temporary Regulations
section 301.9100-22T is in effect.
Section references are to the Internal Revenue Code unless
Purpose of Form
Form 8894 is used only by small partnerships revoking a prior
election to be governed by the unified audit and litigation
procedures as set forth in section 6231(a)(1)(B)(ii) (prior to
amendment by BBA). A “small partnership” is defined as any
partnership having 10 or fewer partners each of whom is an
individual (other than a nonresident alien), a C corporation, or an
estate of a deceased partner. For this pupose, a husband and
wife (and their estates) are treated as one partner.
Note: If the partnership does not qualify as a small partnership
for the tax year shown (after a revocation of the prior election),
a revocation cannot be made and will not be accepted.
Where To File
Form 8894 must be sent to the address below.
Department of the Treasury
Internal Revenue Service Center
Ogden, UT 84201
The form must be filed at the address listed above by the due
date (including extensions) of the partnership return for the tax
year shown. Notification will be sent as to the acceptance or
denial of the request for revocation.
Who Must Sign
Each partner who holds or held an interest in the partnership
during the tax year for which the revocation is filed must sign
the form. This includes all partners during the year, not just
those who were partners at the end of the tax year. This will be
deemed to have occurred if all partners listed on the Schedules
K-1 of the Form 1065 filed for the revocation year, sign the
A husband and wife are generally considered as one partner,
and should both sign the election. One spouse may sign for the
other if acting under a power of attorney, which, if not previously
filed, must accompany this form. Corporate partners should
name the corporation, with the signature of the appropriate
corporate officer. Attach a continuation sheet if more signature
space is needed.
Paperwork Reduction Act Notice
We ask for the information on this form to carry out the Internal
Revenue laws of the United States. You are required to give us
the information. We need it to ensure that you are complying
with these laws and to allow us to figure and collect the right
amount of tax.
You are not required to provide the information requested on
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as long as their contents may become material in the
administration of any Internal Revenue law. Generally, tax
returns and return information are confidential, as required by
The time needed to complete and file this form will vary
depending on individual circumstances. The estimated burden
for business taxpayers filing this form is approved under OMB
control number 1545-0123 and is included in the estimates
shown in the instructions for their business income tax return.