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:
- Compose a brief note to serve as a fax cover sheet explaining the issue, with contact information for an IRS follow-up.
- Attach a copy of the 972CG Notice sent to the institution.
- 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.