Thans so much to sjrcpa .... For anyone reading this thread .... name the pdf form to be attached and provide the description of the attachment EXCLUDING the word "FORM" ... seriously messed up .... 

I changed the name of the pdf to .... "8082 Document Challenge xxx" .... and used that as the description of the attachment .... and the return eFiled with the IRS without another hiccup ...

I have other returns that kept rejecting attachments, for reasons other than having to attach a Form 8082 but still related to some aspect of a Form that was not accessible within Proseries ... and it appears that this "fix" works for those issues as well.