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NACUBO recently learned that several colleges and universities have received 972CG penalty notices related to missing or inaccurate Taxpayer Identification Numbers (TINs) on IRS Form 1098-T for tax year 2016.

At a recent meeting of the Information Reporting Program Advisory Committee, IRS officials said that it was not their intention to send notices to schools that had checked a box indicating they had taken the proper steps to collect student TINs. This box is only on the form that institutions submit to the IRS; it does not appear on the form students receive.

If an institution receives a 972CG Notice related to missing or inaccurate TINs even after checking the appropriate box on the form, as required in the regulations to be eligible for a penalty waiver, staff should take the following steps:

  1. Compose a brief note to serve as a fax cover sheet explaining the issue, with contact information for an IRS follow-up.
  2. Attach a copy of the 972CG Notice sent to the institution.
  3. Fax both documents to the IRS Office of National Public Liaison at 855.834.2801.

No further action is required after sending the documents.

If a penalty notice was received and the institution did not check the box indicating it had properly solicited a student TIN, staff should follow the guidance in NACUBO Advisory Report 2013-1 (beginning on page 9) for information on how to respond to the IRS.

Additional Resources Available

A comprehensive list of Form 1098-T resources is available on NACUBO’s website.


Bryan Dickson

Assistant Director, Advocacy and Student Financial Services



Mary Bachinger

Director, Tax Policy


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