IRS Waives Penalties for Missing or Incorrect TINs for Colleges and Universities

The IRS is giving colleges and universities a pass if they’ve filed Form 1098-T with an incorrect or missing taxpayer identification number (TIN).

The associated penalties assessed against any college, university, or other educational institution will be waived for 2012 and won’t be assessed for 2013 and 2014 tax years. If an educational institution was assessed a penalty for tax year 2012, the IRS will send a letter informing the institution of its decision. If a letter isn’t received by October 1, 2015, the institution should respond to the IRS using the original penalty assessment notice and request relief (or rerequest, if a response was already sent).

This move was made after legislation was passed this summer as part of the fast-track trade authority legislation that provides penalty relief to educational institutions for statements issued after December 31, 2015, with missing or incorrect TINs. It applies only if the institution certifies under penalty of perjury that it’s complied with regulations governing solicitation of payee TINs, according to the IRS Web site. This legislation doesn’t require any changes to current Form 1098-T processing requirements, so institutions are still required to solicit payee TINs.


If your college or university was assessed penalties in 2012 or filed Form 1098-T with an incorrect or missing taxpayer TIN, Moss Adams can help you respond to the IRS and navigate the waiver process. In the meantime, for more information about penalties associated with Form 1098-T, contact your Moss Adams tax professional.

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