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Business and Policy Areas
Business and Policy Areas

IRS Again Issues 1098-T Fine Notices

August 22, 2014

Colleges and universities have reported receiving notices of proposed fines from the Internal Revenue Service for filing Form 1098-T with missing or incorrect taxpayer identification numbers relating to forms filed for the 2012 tax year. Hundreds of institutions received similar notices last summer for 2011 forms, with proposed fines reaching as high as $1 million in some cases. NACUBO succeeded in persuading the IRS to waive all fines related to the 2011 Form 1098-Ts. Many institutions are still waiting for formal notice that the 2011 fines have been waived.

NACUBO had been assured by IRS officials this spring that the agency would reprogram its systems so that similar notices would not go out this year but this does not seem to have happened. We believe the oversight was unintentional and are working with the IRS to try to find a solution that will avoid the labor-intensive process of institutions requesting and IRS approving waivers on a one-by-one basis. In the meantime, NACUBO recommends that members either:

  • Wait a few weeks before taking any action, to see if the matter will be resolved
  • Request an extension to the 45-day period provided for response
  • Go ahead and file a request for a waiver

NACUBO Advisory Report 2013-1, prepared last year in response to the 2011 notices, provides background information and guidance on responding to the IRS. 


Anne Gross
Vice President, Regulatory Affairs

Mary Bachinger
Director, Tax Policy