2025 Grant Application Package and Guidelines
 

LOW INCOME TAXPAYER CLINICS

TABLE OF CONTENTS

 

APRIL 2024
 

DEAR PROSPECTIVE LOW INCOME TAXPAYER CLINIC GRANT APPLICANT: 

I am excited to announce the opening of the 2025 Low Income Taxpayer Clinic (LITC) grant application period 

at a time when the IRS is implementing key initiatives that are part of its Strategic Operating Plan to improve 

taxpayer service and provide additional assistance to taxpayers and tax professionals. The application period 

will begin on April 22, 2024, and conclude on June 12, 2024. We are eager about the prospect of increasing 

geographic coverage, providing more service to taxpayers, and adding additional LITCs for the new grant 

year. The work of the LITCs has a significant impact on the taxpayers they serve. In 2022, IRS-funded tax 

clinics helped nearly 20,000 low-income taxpayers resolve their issues with the IRS and provided consultations 

to over 15,000 more taxpayers. They conducted over 1,400 educational activities, educating nearly 57,000 

taxpayers about a variety of tax topics, including their rights and responsibilities as U.S. taxpayers. They also 

elevated 115 systemic issues to the Taxpayer Advocate Service to help ensure the fairness and integrity of the 

U.S. tax system for all taxpayers. 

For fiscal year (FY) 2024, Congress has provided overall LITC grant funding of $28 million and has authorized 

funding of up to $200,000 per clinic. The President’s 2025 budget request proposes an overall LITC 

grant funding level of $26 million and a continuation of the $200,000 per-clinic funding cap. In light of 

the President’s budget request and the uncertain timeline for final congressional action, the IRS will allow 

applicants to request up to $200,000 for the 2025 grant year. The IRS will also continue the ESL Education 

Pilot Program that was rolled out as part of the February 2023 supplemental funding opportunity. If for 2025 

Congress significantly reduces the overall LITC grant funding level or reduces the per-clinic funding cap, the 

IRS will adjust each grant recipient’s award to reflect any limitations in place at that time. 

The IRS remains committed to achieving maximum access to representation for low-income taxpayers, 

education for ESL taxpayers, and receiving feedback from LITCs through their advocacy on issues that impact 

these taxpayers. In awarding 2025 LITC grants, we will continue to work toward the following program goals: 

n	Expanding coverage in areas identified as underserved; and 

n	Ensuring grant recipients demonstrate they are serving geographic areas with sizable populations 

eligible for and requiring LITC services. 

IRS Publication 3319 outlines the eligibility requirements for LITC matching grants and provides application 

instructions. This publication, including the appendices, is a good reference for LITC grant recipients and 

includes program and administrative guidance for the grant year. 

The IRS may award grants to qualifying organizations for up to a three-year period. However, funding is 

provided for one-year budget periods (January 1 - December 31), subject to the availability of annually 

appropriated funds provided by Congress. Generally, first-time applicants will only be awarded a single-year 

grant, unless the Notice of Funding Opportunity indicates otherwise to encourage applicants in areas with 

limited or no LITC coverage. For all awards, every dollar of federal funds provided by the IRS must be matched 

with cash from non-federal sources or third-party in-kind contributions. 

All Full Grant Applications and Non-Competing Continuation (NCC) Requests must be submitted 

electronically by 11:59 p.m. Eastern Time (ET) on June 12, 2024, via www.grants.gov or 

https://home.grantsolutions.gov/home. The cost of preparing and submitting applications and NCC Requests 

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is the responsibility of each applicant. On April 25, 2024, and May 7, 2024, from 1:00 pm to 2:30 p.m. ET, the 

LITC Program Office will host webinars for organizations interested in submitting a full application or learning 

more about the application process. For more information, including a link to register for the webinar, visit 

www.taxpayeradvocate.irs.gov/about-us/litc-grants. This webpage also includes a guidance document to 

help applicants with completing Form 13424-M, Low Income Taxpayer Clinic Application Narrative. Existing 

LITCs submitting an NCC Request should check the LITC Toolkit for the date and time of a session on that 

specific topic. 

Qualified applicants will be notified in October 2024 of their selection for an award for the 2025 grant year. 

Award recipients must attend the Annual LITC Grantee Conference, which will be held in December 2024. The 

Annual Conference provides an opportunity for new award recipients and returning LITCs to meet, network, 

share best practices, and obtain substantive training on tax law topics relevant to low-income and ESL 

taxpayers. Award recipients will be notified of the conference dates as soon as they are determined. If you 

have questions about the LITC Program or grant application process, please contact the LITC Program Office 

at 202-317-4700 (not a toll-free call) or by email at LITCProgramOffice@irs.gov. 

We appreciate your interest in the LITC Program, and we look forward to another successful grant 

year as we work to help LITCs ensure the fairness and integrity of the tax system for low-income and 

ESL taxpayers. 

Sincerely, 

Erin M. Collins 

National Taxpayer Advocate 
LOW INCOME TAXPAYER CLINICS

TABLE OF CONTENTS

WHAT’S NEW THIS YEAR

Below is a list of changes made to the program for the 2025 grant year with a cite to the relevant text in the 

publication; however, all are encouraged to read the entire publication. By accepting the Notice of Award, all 

grant recipients are agreeing to follow the guidelines provided in this publication. 

n	The areas (states and counties) of special consideration where there are no clinics or very limited 

coverage for the 2024 grant year have been updated. (Page 2) 

n	The chart of important dates has been updated, including the dates for several informational 

webinars to help organizations navigate the application process. (Page 3) 

n	Wherever the Publication (including any Forms and Instructions) references that the maximum annual 

federal funding available is $100,000, please substitute $200,000. This increase is included in the 

President’s fiscal year 2025 Budget Request. If the amount differs when Congress appropriates 

funds, the LITC Program Office will adjust all awards accordingly. (Page 3 and throughout) 

n	The IRS will continue the ESL Education Pilot Program that was rolled out as part of the February 

2023 supplemental funding opportunity. (Page 12) 

n	The expenditure threshold to trigger a single audit has been increased from $750,000 to $1,000,000, 

see 2 CFR § 200.501. (Pages 17, 18, 30, 94, and 95) 

n	The de minimis rate under 2 CFR § 200.414(f) of the Uniform Guidance, has changed from 10 percent 

to 15 percent. (Page 26) 

n	The “Special Rule for Valuing Volunteer Services of a Qualified Representative” section was updated. 

For the 2024 calendar year, the maximum rate at which to value services provided by a qualified 

representative is $240 per hour, as prescribed in Revenue Procedure 2023-34, 2023-48 I.R.B. 1287, 

unless the representative can establish that a special factor, as described in IRC § 7430(c)(1)(B)(iii), 

applies. (Page 30) 

n	The following language was added to the Qualified Business Administrator (QBA) section: A grantee 

may outsource part of its accounting function, but a staff member must still be designated as 

the QBA. (Page 38) 

n	Due to the change in the definition of Equipment at 2 CFR 200.1, the “Recordkeeping and File 

Management, Maintaining Records of Grant Expenditures” paragraph was updated in two places: 

The absence of prior written approval of any element of cost will not affect the reasonableness 

or allocability of that element, unless prior written approval is specifically referenced under 

2 CFR § 200.407, such as purchases of $10,000 or more described in 2 CFR § 200.439(b)(2). Copies 

of any pre-approvals should be retained for three years from the date of purchase. Purchases of 

$10,000 or more should be noted in the clinic’s financial narrative in the year purchased. (Page 47) 

n	Figure 6, LITC Income Guidelines, was updated to reflect annual updates to the federal poverty 

guidelines. (Page 52) 

n	In both the Equipment and Supplies sections, the threshold amount was increased from $5,000 to 

$10,000. (Page 110) 

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WHAT’S NEW THIS YEAR 

AVOIDING COMMON ERRORS AND MISSTEPS WHEN APPLYING

To assist with the application process, see the list below of commonly made errors and missteps. Please 

double check your Full Grant Application or NCC Request to avoid these errors and ensure your application 

is timely processed and reviewed. 

Standard Form 424 

n	Legal name does not match the legal name in SAM.gov (Item 8a).

n	The Employer Identification Number (EIN) provided does not match the EIN in SAM.gov (Item 8b).

n	Missing attachment listing counties covered (Item 14).

n	Missing attachment listing congressional districts covered (Item 16b).

n	Requesting a multiyear grant utilizing the wrong proposed project end date (Item 17b).

n	Missing the amount(s) of matching funds to be provided (Items 18b-f).

Form 13424-M 

n	Applicants indicate a single audit was “Qualified” when it was described as “Unqualified” and 

therefore the correct selection on the form is “Unmodified.” 

n	No responses or incomplete responses are provided in the Civil Rights Review section; in particular, 

the response to question D should address both the needs of individuals with limited English 

proficiency (LEP) and those who may need a reasonable accommodation to access services. “Not 

Applicable” is not an appropriate response because the questions apply to all organizations. 

Form 13424-J 

n	Returning applicants prepare the new grant year budget working off the one submitted with the 

original application the prior year instead of working off the one approved during the application 

amendment process. Working off the approved budget will ensure that the same errors are not 

made again. 

n	No full-time equivalent (FTE) is provided for staff on Form 13424-J, Detailed Budget Worksheet and 

Narrative Explanations, or applicants fail to state how many hours per week is considered full-time. 

The Personnel section of the Detailed Budget Narrative Explanations should start with a statement 

defining how many hours constitute a work week; for example, “ABC clinic computes 1.0 FTE on a 

40-hour work week (2,080 hours per year).” 

n	There is no breakdown of travel and training expenses into categories such as lodging, 

transportation, and meals and incidentals.
 

Project Abstract (for NCC Requests only) 

n	The form is missing the four primary numerical goals:
 

n	New representation cases to be opened in the calendar year;

n	Consultations with low-income and ESL taxpayers;

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vi LOW INCOME TAXPAYER CLINICS

n	Educational activities to low-income and ESL taxpayers; and 

n	Low-income and ESL taxpayers to be reached in educational activities. 

n	Program Plan changes are not addressed. If there are no changes, include a statement indicating 

no changes. “Not Applicable” is not an acceptable response because the question applies to all 

organizations. 

n	No responses or incomplete responses are provided in the Civil Rights Review section; in particular, 

the response to question D should address both the needs of individuals with LEP and those who 

may need a reasonable accommodation to access services. “Not Applicable” is not an appropriate 

response because the questions apply to all organizations. 

Employer Identification Number and System for Award Management Registration 

Applicants fail to apply early enough to the IRS to receive an EIN, which is needed to complete the SAM.gov 

registration process. SAM registration is a multi-step process that can take four to six weeks to complete. 

Attachments 

n	The Indirect Cost Rate Agreement (ICRA) submitted by applicants is incomplete or expired. To 

determine whether the ICRA is properly applied, the LITC Program Office must know what costs were 

included in the Modified Direct Costs so this part of the agreement should be supplied. If the ICRA is 

expired, the applicant should provide an explanation including whether an extension was requested 

and, if so, the date it was requested. 

n	The tax-exempt determination letter (if applicable) is not provided.

n	The letter of accreditation, for academic institutions, is not provided.
 

n	An incomplete copy of the single audit is submitted or the copy is missing (and it is unavailable on the 

Federal Audit Clearinghouse website). 

n	The Tax Compliance Officer substantiation documentation is not attached or is insufficient. 
LOW INCOME TAXPAYER CLINICS

TABLE OF CONTENTS

 

 

 

 

TABLE OF CONTENTS

WHAT’S NEW THIS YEAR .............................................................. iii
 

AVOIDING COMMON ERRORS AND MISSTEPS WHEN APPLYING ....................... v
 

I. LITC PROGRAM DESCRIPTION...................................................... 1
 

A. LITC Grant Program Priorities..................................................... 1
 

B. History of the LITC Program...................................................... 3
 

C. Statutory Authority to Fund LITCs ................................................. 4
 

D. Key Terms and Definitions ....................................................... 5
 

II. FEDERAL AWARD INFORMATION ..................................................10
 

A. Awards Are Subject to Congressional Appropriations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
 

B. Award Performance Period...................................................... 10
 

C. Subawards Are Generally Prohibited...............................................11
 

D. LITC Grants Are Not Cooperative Agreements.......................................11
 

III. AWARD ELIGIBILITY REQUIREMENTS ..............................................12
 

A. Eligible Applicants ............................................................. 12
 

B. Requirement to Provide Matching Funds Equal to Award ............................. 13
 

C. Other Eligibility Requirements ................................................... 13
 

i.	 Using Grant Funds to Support Other Activities is Prohibited ....................... 13
 

ii.	 Charging More Than a Nominal Fee for Services Is Prohibited ..................... 13
 

iii. Compliance With Federal Tax and Nontax Requirements .......................... 13
 

iv. Debarment and Suspension.................................................. 15
 

IV. APPLICATION AND SUBMISSION PROCESS .......................................16
 

A. Accessing the LITC Grant Application Package and Guidelines ........................ 16

B. Required Content for LITC Full Grant Applications and Non-Competing Continuation 

Requests .................................................................... 16

i. Determining Type of Application .............................................. 16

ii.	 Submitting a Full Grant Application on Grants.gov ............................... 16

iii. Instructions for Completing Full Grant Application ............................... 17
 

iv. Submitting a Non-Competing Continuation Request ............................. 18

v. Instructions for Completing a Non-Competing Continuation Request ............... 18

vi. Withdrawing Applications After Submission .................................... 19
 

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C. System for Award Management Registration Requirement and Unique Entity Identifiers ... 19
 

i.	 System for Award Management .............................................. 19
 

ii. Employer Identification Number .............................................. 20
 

iii. Unique Entity Identifier...................................................... 20
 

iv. Organization Name Change Requests ......................................... 20
 

D. Submission Due Dates and Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
 

i. Due Date for LITC Full Grant Applications and Non-Competing Continuation 

Requests ................................................................. 20
 

ii.	 Incomplete or Late LITC Full Grant Applications and Non-Competing Continuation 

Requests ................................................................. 21
 

E. Budget Considerations and Funding Restrictions ................................... 21
 

i.	 Spending LITC Grant Funds and Matching Funds ................................ 21
 

ii. Direct vs. Indirect Expenses ................................................. 24
 

iii. Meeting the Matching Funds Requirement ..................................... 27
 

iv. Office of Management and Budget Audit Requirement ........................... 30
 

V. APPLICATION REVIEW ............................................................ 32
 

A. Technical Evaluation of Full Grant Applications and Scoring Criteria .................... 32
 

B. LITC Program Office Evaluation and Selection of Full Grant Applications and 

Non-Competing Continuation Requests ........................................... 33
 

i. LITC Program Office Evaluation .............................................. 33
 

ii.	 Civil Rights Compliance Reviews.............................................. 35
 

VI. AWARD ADMINISTRATION .........................................................37
 

A. Notification of Selection ........................................................ 37
 

B. Notice of Award............................................................... 37
 

C. Administrative Requirements .................................................... 38

i.	 Standards for Operating a Low Income Taxpayer Clinic ........................... 38

ii.	 Low Income Taxpayer Clinic Program Office Webinars............................ 40
 

iii. Annual Low Income Taxpayer Clinic Grantee Conference ......................... 41
 

iv. Developing a Community Outreach Plan ....................................... 42
 

v.	 Building Community Partnerships ............................................. 43
 

vi. Networking With Other Low Income Taxpayer Clinics ............................ 44
 

vii. Mentoring ................................................................ 44
 

viii. Technical Assistance Consultation ............................................ 44
 

ix. Maintaining Client Confidentiality ............................................. 44
 
LOW INCOME TAXPAYER CLINICS ix 

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x. Recruiting and Supervising Volunteers......................................... 46

xi. Recordkeeping and File Management ......................................... 47
 

xii. Representing Low-Income Taxpayers ......................................... 49
 

xiii. Education................................................................. 61

xiv. Advocacy................................................................. 63

xv. Preparing Tax Returns and Individual Taxpayer Identification Number Applications .... 63

D. National Policy Requirements and Administrative Requirements ....................... 64

i. General Compliance ........................................................ 64

ii. Managing Grant Funds ...................................................... 71
 

iii. Lobbying Restrictions....................................................... 72
 

E. Reporting Responsibilities ...................................................... 75
 

i. Events Requiring Notification to the LITC Program Office ......................... 77
 

ii. Submitting the Interim Report ................................................ 79
 

iii. Submitting the Year-end Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

iv. Grant Closeout ............................................................ 81

VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT ...................... 82
 

A. Structure .................................................................... 82

B. Administration ................................................................ 83

C. Assistance ................................................................... 83

D. Oversight .................................................................... 83

E. Site Assistance Visits .......................................................... 84

F. Contacting the LITC Program Office .............................................. 86

VIII.AWARD MODIFICATION, SUSPENSION, TERMINATION, OR WITHDRAWAL ....... 88
 

APPENDIX A .......................................................................... 93
 

APPENDIX B ......................................................................... 127
 

FEDERAL GRANT ACRONYMS .......................................................181
 

GLOSSARY........................................................................... 185
 

INDEX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 195
 
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I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

 

I. LITC PROGRAM DESCRIPTION

A. LITC GRANT PROGRAM PRIORITIES 

LITCs Provide Representation, Education, and Advocacy 

LITCs ensure the fairness and integrity of the tax system for taxpayers who are low-income or speak ESL by: 

n	Providing pro bono representation on their behalf in tax disputes with the IRS; 

n	Educating them about their rights and responsibilities as taxpayers; and 

n	Identifying and advocating for issues that impact these taxpayers. 

LITCs must: 

n	Provide dollar-for-dollar matching funds; and 

n	Offer LITC services for free or for no more than a nominal fee. See Section I.D, Key Terms and Definitions. 

In December 2015, Congress enacted the Taxpayer Bill of Rights (TBOR)1 in Internal Revenue Code 

(IRC) § 7803(a)(3). TBOR lists rights that already existed in the IRC, putting them in simple language and 

grouping them into ten fundamental rights. One of the ten fundamental rights taxpayers have is the right to 

retain representation,2 meaning taxpayers have the right to retain an authorized representative of their choice to 

represent them in their interactions with the IRS. A taxpayer who cannot afford to hire a representative has the 

right to be informed about their potential eligibility for assistance from an LITC. The LITC Program provides 

free or low-cost access to representation for low-income taxpayers, so that achieving a correct outcome in an IRS 

dispute does not depend on a taxpayer’s ability to pay for representation. 

LITC Program Coverage 

The IRS is committed to achieving maximum access to clinic services for low-income taxpayers under this grant 

program. For the 2024 grant year, however, there are several geographic areas of the country without an LITC or 

with very limited coverage. Thus, in awarding 2025 LITC grants, we will strive to provide services to low-income 

and ESL taxpayers in every state, the District of Columbia, and Puerto Rico. We will prioritize the funding of 

qualified applicants to open new clinics or expand existing LITC coverage in geographic areas with no clinic or very 

limited coverage (see list below) before adding a new clinic in a geographic area that already has a clinic or coverage. 

Coverage of an area requires more than a willingness to accept a case from an area but requires that an organization 

take steps to promote itself as being available and willing to provide the full range of LITC services for that area. 

1 See Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, Division Q, § 401, 129 Stat. 2242, 3117 (Dec. 18, 2015). 

2 See IRC § 7803(a)(3)(I). 
LOW INCOME TAXPAYER CLINICS

Areas of Special Consideration 

Hawaii, Kansas, Nevada, North Dakota, South Dakota, and West Virginia and the territory of Puerto Rico 

currently do not have an LITC. In addition, two states – Florida and Montana – have only partial coverage. The 

uncovered counties in Florida are Citrus, Hamilton, Hernando, Lafayette, Madison, Nassau, St. Johns, Sumter, 

Suwannee, Taylor, Brevard, Lake, Orange, Osceola, Seminole, and Volusia. The uncovered counties in Montana 

are Blaine, Broadwater, Carbon, Carter, Custer, Daniels, Dawson, Deer Lodge, Fallon, Fergus, Flathead, Garfield, 

Golden Valley, Granite, Jefferson, Judith Basin, Lincoln, Madison, McCone, Mineral, Missoula, Musselshell, 

Petroleum, Phillips, Pondera, Powder River, Powell, Prairie, Richland, Sanders, Sheridan, Stillwater, Sweet Grass, 

Toole, Treasure, Valley, Wheatland, and Wibaux. 

Figure 1, 2024 LITC Coverage by County 

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LOW INCOME TAXPAYER CLINICS

LITC PROGRAM DESCRIPTION

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

 

Important Dates for 2025 LITC Grant Program 

Application Period April 22-June 12, 2024 

New Applicant Webinar, Session 1 April 25, 2024 

New Applicant Webinar, Session 2 May 7, 2024 

Returning Applicant/ NCC Request Webinar May 9, 2024 

Application Q&A Webinar June 6, 2024 

Application Review and Evaluation June-October 2024 

Notification of Selection/Non-Selection October 2024 

Grant Year January 1-December 31, 2025 

Interim Report Due July 31, 2025 

Year-end Report Due March 31, 2026 

B. HISTORY OF THE LITC PROGRAM 

As part of the IRS Restructuring and Reform Act of 1998, Congress enacted IRC § 7526 to authorize funding for 

the LITC Program.3 The IRS created the LITC Program Office in 1999 to award and administer the grants and 

provide guidance, assistance, and oversight to LITCs and prospective applicants. The LITC Program Office is part 

of the Office of the Taxpayer Advocate (commonly referred to as the Taxpayer Advocate Service (TAS)), and TAS 

is led by the National Taxpayer Advocate (NTA), who reports to the IRS Commissioner. 

In 1999, the IRS awarded grants totaling nearly $1.5 million to 34 entities in 18 states and the District of 

Columbia. Since inception, the LITC Program has expanded its coverage and in 2024 there are 131 clinics funded 

with nearly $13 million.4 The LITC Program Office’s history of recruiting coupled with sound judgment in 

selecting federal grant recipients has fostered the growth of a nationwide network of independent organizations 

working toward a common purpose in their local communities. The maximum statutory award amount of 

$100,000 per clinic had remained constant since the creation of the program until recently with the passage of the 

2023 appropriations legislation when it was increased to $200,000. That increase has been continued in the 2024 

appropriations legislation and also in the President’s FY 2025 budget proposal. Despite the funding limitation, 

LITCs have consistently delivered tremendous results, new clinics join each year, and the program continues to 

expand coverage into underserved areas of the country. 

3 See IRS Restructuring and Reform Act of 1998, Pub. L. No. 105-206, § 3601, 112 Stat. 685, 774 (July 22, 1998). 

4 The LITC Program Office announced a supplemental funding opportunity in February 2024. At the time this publication 

went to print, award decisions on those applications had not been made. Thus, the 131 clinics funded with nearly 

$13 million is not the final funding statistics for the LITC Program for 2024. 

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4 LOW INCOME TAXPAYER CLINICS

C. STATUTORY AUTHORITY TO FUND LITCs 

The authority to fund the development, expansion, or continuation of LITCs is derived from IRC § 7526. The 

text of IRC § 7526 is reprinted in full below: 

Section 7526. Low-income taxpayer clinics. 

(a)	 In general. The Secretary may, subject to the availability of appropriated funds, make grants to provide 

matching funds for the development, expansion, or continuation of qualified low-income taxpayer clinics. 

(b)	 Definitions. For purposes of this section­

(1) Qualified low-income taxpayer clinic. 

(A) In general. The term “qualified low-income taxpayer clinic” means a clinic that­

(i)	 does not charge more than a nominal fee for its services (except for reimbursement of actual 

costs incurred); and 

(ii) (I) represents low-income taxpayers in controversies with the Internal Revenue Service; or 

(II) operates programs to inform individuals for whom English is a second language about 

their rights and responsibilities under this title. 

(B) Representation of low-income taxpayers. A clinic meets the requirements of subparagraph (A)(ii)(I) 

if­

(i)	 at least 90 percent of the taxpayers represented by the clinic have incomes which do not exceed 

250 percent of the poverty level, as determined in accordance with criteria established by the 

Director of the Office of Management and Budget; and 

(ii) the amount in controversy for any taxable year generally does not exceed the amount specified 

in section 7463. 

(2)	 Clinic. The term “clinic” includes­

(A) a clinical program at an accredited law, business, or accounting school in which students represent 

low-income taxpayers in controversies arising under this title; and 

(B) an organization described in section 501(c) and exempt from tax under section 501(a) which 

satisfies the requirements of paragraph (1) through representation of taxpayers or referral of 

taxpayers to qualified representatives. 

(3) Qualified representative. The term “qualified representative” means any individual (whether or not an 

attorney) who is authorized to practice before the Internal Revenue Service or the applicable court. 

(c)	 Special rules and limitations. 

(1)	 Aggregate limitation. Unless otherwise provided by specific appropriation, the Secretary shall not allocate 

more than $6,000,000 per year (exclusive of costs of administering the program) to grants under this 

section. 

(2)	 Limitation on annual grants to a clinic. The aggregate amount of grants which may be made under this 

section to a clinic for a year shall not exceed $100,000. 
LOW INCOME TAXPAYER CLINICS 5 

LITC PROGRAM DESCRIPTION

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

(3)	 Multiyear grants. Upon application of a qualified low-income taxpayer clinic, the Secretary is authorized 

to award a multiyear grant not to exceed 3 years. 

(4)	 Criteria for awards. In determining whether to make a grant under this section, the Secretary shall 

consider­

(A) the numbers of taxpayers who will be served by the clinic, including the number of taxpayers in 

the geographical area for whom English is a second language; 

(B) the existence of other low-income taxpayer clinics serving the same population; 

(C) the quality of the program offered by the low-income taxpayer clinic, including the qualifications 

of its administrators and qualified representatives, and its record, if any, in providing service to 

low- income taxpayers; and 

(D) alternative funding sources available to the clinic, including amounts received from other grants 

and contributions, and the endowment and resources of the institution sponsoring the clinic. 

(5)	 Requirement of matching funds. A low-income taxpayer clinic must provide matching funds on a dollarfor-dollar basis for all grants provided under this section. Matching funds may include­

(A) the salary (including fringe benefits) of individuals performing services for the clinic; and 

(B) the cost of equipment used in the clinic. 

Indirect expenses, including general overhead of the institution sponsoring the clinic, shall not be 

counted as matching funds. 

(6)	 Provision of information regarding qualified low-income taxpayer clinics. 

Notwithstanding any other provision of law, officers and employees of the Department of the Treasury 

may­

(A) advise taxpayers of the availability of, and eligibility requirements for receiving, advice and 

assistance from one or more specific qualified low-income taxpayer clinics receiving funding under 

this section, and 

(B) provide information regarding the location of, and contact information for, such clinics. 

D. KEY TERMS AND DEFINITIONS 

90/250 requirement was established by IRC § 7526 and provides that at least 90 percent of the taxpayers 

represented by a clinic have incomes that do not exceed 250 percent of the Federal Poverty Guidelines. The LITC 

Program uses the poverty guidelines published annually by the Department of Health and Human Services. See 

Section VI.C.xii, Representing Low-Income Taxpayers. 

Advocacy as it relates to LITCs is zealously protecting the rights of low-income and ESL taxpayers. Advocacy 

can occur on an individual or systemic basis. A substantial portion of LITC work involves assisting clients with an 

IRS controversy. Clinics advocate for the taxpayers they represent by ensuring they are paying the correct amount 

of taxes, exploring all possible options for relief, and assisting them in making a fully informed decision on how 

best to proceed given the facts of the case and the taxpayer’s situation. Notwithstanding the unique nature of each 
6 LOW INCOME TAXPAYER CLINICS

taxpayer’s circumstances, similarly-situated taxpayers often experience similar problems with tax administration. 

Advocacy includes, but is not limited to, identifying systemic-level issues and sharing them with TAS. TAS 

investigates the submissions, proposes solutions, and works with the IRS to resolve the issues, or elevates them 

to the NTA who can communicate the issues and proposed solutions to lawmakers and the IRS administration 

in her reports to Congress. Advocacy may also include responding to public requests for comments on IRS 

regulations or procedures and filing amicus briefs in cases addressing issues that directly impact low-income and 

ESL taxpayers. 

Amount in controversy is the federal tax amount in dispute for each tax year for which the LITC is representing 

a taxpayer. Often, the amount in controversy is the amount owed or the refund requested. In some disputes 

with the IRS, however, the amount in controversy is the amount associated with an action taken by the IRS. 

The amount in controversy includes the tax liability in dispute for a tax year, plus any related penalties imposed. 

Whether interest is included in the amount in controversy will depend on the nature of the controversy. The 

amount in controversy is limited to the amount in dispute, which may be less than the amount specified in an 

IRS statutory notice of deficiency, a notice of determination, or a notice and demand. If the taxpayer is disputing 

the amount due in more than one tax year or period, the amount in controversy is determined separately for each 

year. See Section VI.C.xii, Representing Low-Income Taxpayers, Amount in Controversy Limit. 

Cases are those matters that LITCs count and report in inventory when a taxpayer or married taxpayers retain 

the clinic to represent them in a controversy before the IRS or a federal court. To be counted as a case, the clinic 

must try to address the controversy, including developing a plan for representation. If the clinic is representing 

a married couple, it is counted as one case. If a taxpayer stops communicating with the clinic after a plan for 

representation has been developed, the clinic may still count that matter as a case. If a clinic refers the matter to a 

qualified representative, it may count the matter as a case so long as it provides ongoing monitoring and support. 

Clinic refers to an LITC. See the definition of LITC below. Throughout this publication, the terms clinic, LITC, 

and grant recipient are used interchangeably. 

Consultation encompasses a discussion with or correspondence to a taxpayer designed to address the taxpayer’s 

unique circumstances and involves an analysis tailored to the taxpayer’s factual situation. A consultation does not 

result in advocating for the taxpayer before the IRS or relevant court in a representative capacity but might include 

fact gathering and contact with the IRS that does not rise to the level of advocacy. 

Controversy with the IRS is a proceeding brought by the taxpayer under the IRC or any dispute between an 

individual and the IRS concerning the determination, collection, or refund of any tax, penalties, or interest. The 

definition is very broad and encompasses all types of disputes arising under the IRC, except criminal tax matters. 

For example, a controversy includes a dispute related to eligibility and receipt of Economic Impact Payments, a 

revocation or denial of a passport under IRC § 7345, and certain civil actions arising under IRC §§ 7431 to 7435. 

The dispute may be pending in a federal court or in any tax administration function of the IRS (e.g., Examination, 

Collection, Appeals, Accounts Management). The dispute does not have to arise under the IRC if the dispute 

is with the IRS; for example, a controversy includes civil penalties arising under Title 31 if the IRS is the other 

party involved in the controversy. While representing a taxpayer in a controversy with the IRS, an LITC may also 

need to represent the taxpayer in a controversy with a state or local tax agency concerning the same or related tax 

matter. Though a controversy does not include a federal criminal tax matter, it may include a state criminal tax 

matter. A controversy may be considered a civil matter in the federal context, but a criminal matter under state or 
LOW INCOME TAXPAYER CLINICS 7 

LITC PROGRAM DESCRIPTION

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

local law. If the LITC is already representing the taxpayer in the federal civil matter, it may be appropriate for the 

LITC to expand the scope of the representation to include the state or local tax matter. 

Educational activities (also referred to as programs to inform) inform ESL or low-income individuals about 

their rights and responsibilities as taxpayers, and tax issues of significance to the intended audience. The two 

education-related numerical goals referenced on Form 13424-M, Application Narrative, VII. Program Numerical 

Goals C and D, reference those activities delivered directly to taxpayers. Educational activities may also include a 

workshop or free training for organizations that assist low-income or ESL taxpayers. While activities delivered to 

organizations are not included in the numerical goals on Form 13424-M, these activities are reported on Form 

13424-A, Low Income Taxpayer Clinic (LITC) General Information Report, and considered by the Program 

Office. To be considered an educational activity, information about a specific tax topic or topics must be conveyed 

to the audience. LITCs should address a wide range of substantive tax issues in their educational programs and 

materials (e.g., filing requirements, tax recordkeeping, family status issues, refundable credits, the Affordable 

Care Act, worker classification, identity theft, information about the audit and appeals process, and collection 

alternatives). Selecting education topics relevant to community needs and offering the presentations and/or 

presentation materials in languages commonly spoken in the community allow LITCs to reach taxpayers who 

otherwise might experience great difficulty communicating with the IRS. These programs are delivered in-person 

to a live audience, with participants registering, signing in, or being counted and allow for audience interaction 

with the presenter. Clinics may also use virtual platforms to deliver these programs and count them as educational 

activities for LITC reporting when there is a way for participants to be counted and for the presenter and 

participants to interact. 

ESL taxpayers are persons for whom English is not their first language, which also includes those who 

communicate using sign language. These individuals may have an additional burden understanding taxpayer rights 

and responsibilities and are a priority for LITC education and outreach efforts. This differs from the term Limited 

English Proficiency (LEP), which relates to an individual’s relative ability to communicate and receive information 

in English. LEP taxpayers are a subset of ESL taxpayers but not all ESL taxpayers are LEP taxpayers. 

Grants.gov is the government website used by federal agencies to post discretionary funding opportunities. 

GrantSolutions is a web-based, comprehensive grant management system. Clinics use GrantSolutions for 

submitting an NCC Request, accepting a Notice of Award (NOA), submitting reports, and reporting program 

plan, staffing, or budget changes. 

Key personnel are individuals necessary for the successful functioning of the LITC. Key personnel are 

responsible for ensuring that the LITC’s day-to-day operations run smoothly, the LITC program is delivered in 

accordance with the terms and conditions of the grant, finances are properly administered, legal arguments are 

sound, and educational materials are accurate. Key personnel include the Clinic Director, Qualified Tax Expert 

(QTE), and Qualified Business Administrator (QBA). See Section VI.C.i, Standards for Operating a Low Income 

Taxpayer Clinic. 

Low-income taxpayers are individuals whose income does not exceed 250 percent of the Federal Poverty 

Guidelines. The Federal Poverty Guidelines are updated annually (usually in late January) by the Department of 

Health and Human Services (HHS). The LITC Income Guidelines, current as of publication, can be found in 

Section VI.C.xii, Representing Low-Income Taxpayers. A sole proprietor is considered an individual and may be 
8 LOW INCOME TAXPAYER CLINICS

assisted by an LITC if otherwise eligible. A business or other entity is not a low-income taxpayer eligible for LITC 

representation. An individual trying to resolve a tax liability arising from personal involvement with a business can 

be a low-income taxpayer. For example, an individual who is personally liable for taxes owed from a business (e.g., 

a responsible person within the meaning of IRC § 6672) may be a low-income taxpayer, provided the individual 

otherwise meets the definition. 

LITC is an organization receiving a grant pursuant to IRC § 7526. 

Nominal fee is a fee that is insignificantly small or minimal. A nominal fee is a trivial payment, bearing no 

relation to the value of the representation provided, considering all the facts and circumstances. A nominal fee 

must be a flat fee; the fee cannot fluctuate based on an hourly rate or the type of services the LITC is providing. 

A nominal fee does not include reimbursement for actual costs incurred (e.g., photocopies, court costs, and expert 

witness fees). 

Outreach is an activity conducted by an LITC that involves effectively publicizing and promoting the clinic’s 

services regarding representation, education, and advocacy on behalf of low-income and ESL taxpayers. LITCs 

are encouraged to identify linguistic populations, geographic service areas, or other segments of the low-income 

taxpayer community in which to focus outreach efforts. Outreach activities may involve direct communication 

(in-person contact or in writing) with taxpayers or may be accomplished through contacts with other 

organizations or groups that assist low-income and ESL taxpayers. Additional guidance on effective outreach can 

be found in Section VI.C.iv, Developing a Community Outreach Plan. Outreach plans should be developed before 

the start of the grant year during which representation and other assistance will be offered. 

Pro bono panel is a group of qualified representatives (attorneys, certified public accountants (CPAs), or 

enrolled agents (EAs)) who have agreed to accept taxpayer referrals from an LITC and provide representation or 

consultation services free of charge to low-income or ESL taxpayers. Clinics may also use volunteers to assist with 

other tasks such as education, outreach, or mentoring students. 

Program plan is a description of the clinic’s planned operations, including a description of the services to be 

offered; how, when, and where the services will be delivered; who will provide the services; the intended recipients 

of the services; and numerical goals. The terms and conditions of an LITC grant include the applicant’s program 

plan and any subsequent changes to the plan agreed upon between the Program Office and the clinic. 

Qualified representative is: 

n	An attorney; 

n	A CPA; 

n	An EA authorized to practice before the IRS; 

n	An individual authorized to appear before the court where the controversy with the IRS will be adjudicated; or 

n	An individual authorized to practice before the IRS pursuant to 31 Code of Federal Regulations 

(CFR) § 10.7(d) (e.g., a student, law graduate, tribal court advocate, or other individual for whom the IRS 

has issued a special appearance authorization). See Section VI.C.xii, Representing Low-Income Taxpayers, 

Representation by Students and Law Graduates. 
LOW INCOME TAXPAYER CLINICS 9 

LITC PROGRAM DESCRIPTION

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

For individuals other than students or law graduates, the IRS Commissioner (or delegate) has the authority to 

issue special appearance authorizations to allow them to practice before the IRS. For students and law graduates, 

the Director of the LITC Program has the authority to issue special appearance authorizations; note, however, that 

the student or law graduate must be supervised by a qualified representative. See Delegation Order 25-18 (Rev. 5), 

Internal Revenue Manual (IRM) 1.2.2.15.18. 

NOTE: An unenrolled return preparer who can practice before the IRS based upon return preparation is not a 

qualified representative for the LITC Program because the authority of the unenrolled return preparer to act as 

a representative is limited to only certain taxpayers and select functions of the IRS. For details regarding limited 

practice before the IRS by individuals who are not attorneys, CPAs, or EAs, see Rev. Proc. 2014-42, 2014-29 

I.R.B. 192. 

Referral means the referral of low-income taxpayers to qualified representatives or to an LITC for representation. 

Uniform Guidance refers to 2 CFR Part 200 (and the Treasury Department’s implementation thereof, found at 

2 CFR Part 1000), which contains uniform administrative requirements that relate to the pre-award, post-award, 

closeout, and audit phases of the federal grant life cycle. See Section VI.D, National Policy Requirements and 

Administrative Requirements, for a more detailed discussion. 

Additional terms and definitions are available in the Glossary. 
How the LITC Program Receives Its Funding

LOW INCOME TAXPAYER CLINICS

II. FEDERAL AWARD INFORMATION 

A. AWARDS ARE SUBJECT TO CONGRESSIONAL APPROPRIATIONS 

All awards are subject to the availability of appropriated funds. The IRS anticipates awarding LITC grants of up 

to $200,000 per year to qualifying organizations for the development, expansion, or continuation of an LITC. 

Congress appropriated not less than $28 million for LITC grant awards for fiscal year 2024.5 Given the timing of 

appropriations, grant funds may not be made available to grant recipients until after the grant year has begun. The 

IRS also holds some of the annually appropriated funds in reserve so well-performing clinics that were not initially 

awarded the maximum award may ask for additional funds at mid-year. Figure 2 explains how the LITC Program 

receives its funding. 

Figure 2, How the LITC Program Receives Its Funding 

Step One 

Step Two 

Step Three 

Step Four 

Office of Management and 

Budget coordinates with 

federal agencies to 

formulate the President’s 

Budget, which covers all 

federal agencies, including 

the IRS, and reflects the 

President’s priorities and 

vision for the country. 

Federal law requires that 

the President submit a 

budget proposal to 

Congress between the first 

Monday in January and the 

first Monday in February, 

which serves as a starting 

point for negotiations 

in Congress. 

Congressional appropriations 

committees consider the 

President’s Budget as they 

prepare appropriations 

legislation for the upcoming 

fiscal year, which begins on 

October 1. 

The appropriations 

committees submit 

legislative proposals which 

are brought to the floor for 

consideration by the House 

of Representatives and the 

Senate. Once the House 

and the Senate consider 

the proposals and reconcile 

them, Congress passes a 

unified omnibus budget 

and sends the legislation 

to the President to be 

signed into law. 

The President signs the 

appropriations bill into law, 

making funds available to 

executive agencies, 

including the IRS. 

B.	‰AWARD PERFORMANCE PERIOD 

The LITC Program may award grants for up to a three-year period. However, funding is provided for one-year 

periods (January 1–December 31), subject to the availability of annually appropriated funds. Generally, first-time 

applicants will only be awarded a single-year grant. Multiyear grants will only be awarded to applicants that have 

successfully completed at least one year under the terms and conditions of the LITC grant unless the Notice of 

5	 Further Consolidated Appropriations Act, 2024, Pub. L. No. 118-47, Div. B (March 23, 2024). Although funds are 

appropriated for a fiscal year, the Program Office awards grants on an annual basis. 

10 
LOW INCOME TAXPAYER CLINICS 11 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

FEDERAL AWARD INFORMATION

II. FEDERAL AWARD INFORMATION III IV

V VI VII I III IV

V VI VII VIII

 

Funding Opportunity indicates otherwise. Determination of the grant period is at the discretion of the LITC 

Program Office. Thus, the Program Office may elect to award a single-year grant to applicants that requested a 

multiyear grant. 

Multiyear grant recipients will be reviewed annually for satisfactory performance and progress in meeting goals 

and objectives and compliance with grant terms and conditions. The funding level for subsequent years will be 

reviewed annually and may be increased or decreased at the discretion of the LITC Program Office, based on 

performance, compliance with grant terms and conditions, and the availability of annually appropriated funds. 

Funds awarded must be used for the program specifically authorized in the NOA. 

C. SUBAWARDS ARE GENERALLY PROHIBITED 

Generally, a clinic may not make a subaward of LITC grant funds to another organization or individual. A 

subaward is a payment to another organization or contractor to deliver a key component of the program such as 

controversy representation or ESL education. Subawards may be considered if the award of a subgrant is likely to 

assist a grant recipient with expanding coverage to an underserved or uncovered area. Use of a subaward must be 

proposed in the application and approved in writing by the Director of the LITC Program. A subaward differs 

from payments made to a vendor or provider for providing goods and services to the clinic, which is permissible. 

For example, unless authorized, an LITC may not pay another organization to prepare and conduct its ESL 

educational activities; however, the clinic could pay a firm to translate its educational materials into another 

language or hire an interpreter to assist with delivery of education. If a sponsoring organization is located in a 

different geographic area from the service area and has capacity to provide services remotely such as representation 

and advocacy services but needs a local presence to facilitate client contact and provide in-person education and 

outreach, the subaward of funds to a local organization to deliver some of these services may be appropriate where 

the proposed area to be covered is either underserved or uncovered. 

NOTE: In accordance with 2 CFR § 25.300(a), a clinic may not make a subaward unless the subrecipient 

has obtained and provided to the clinic a unique entity identifier (the identifier assigned by SAM.gov to 

uniquely identify business entities). Grant recipients who make subawards must monitor and manage the 

subaward recipient per the requirements in 2 CFR § 200.332 and may have other administrative and reporting 

responsibilities. Organizations that provide subawards assume the responsibilities of the federal grantor regarding 

the subaward recipient. 

D. LITC GRANTS ARE NOT COOPERATIVE AGREEMENTS 

Funds awarded under IRC § 7526 create grant agreements rather than cooperative agreements between the 

recipient and the IRS. A cooperative agreement provides for substantial involvement between the federal awarding 

agency and the grant recipient in carrying out the activity contemplated by the federal award. While the LITC 

Program Office has numerous responsibilities in administering the grant and providing oversight and assistance 

to clinics, that involvement does not result in the formation of a cooperative agreement. See the definitions of 

“cooperative agreement” and “grant agreement” in 2 CFR § 200.1, Definitions, for additional details. 
12 LOW INCOME TAXPAYER CLINICS

 

 

 

 

 

 

 

III. AWARD ELIGIBILITY REQUIREMENTS 

Applicants that fail to satisfy the eligibility screening criteria described below will be notified and, in some 

circumstances, may be provided an opportunity to correct the problem. Those provided an opportunity must 

correct the problem in a timely manner or be eliminated from consideration. Applications that pass the eligibility 

screening will then undergo a technical evaluation. See Section V, Application Review. 

A. ELIGIBLE APPLICANTS 

IRC § 7526 broadly defines the concept of a clinic to include: 

1) A clinical program at an accredited law, business, or accounting school whose students represent low-income 

taxpayers in controversies with the IRS under the supervision of a qualified representative (and when necessary, 

refer to qualified volunteers to provide representation when the students cannot do so); 

2) An organization whose employees and volunteers represent low-income taxpayers in controversies with the 

IRS; 

3) An organization exempt from tax under IRC § 501(a) whose employees and volunteers represent low-income 

taxpayers in controversies with the IRS or refer low-income taxpayers to qualified representatives to provide 

representation; 

4) An organization described in examples 1), 2), or 3) that also operates a program to inform ESL taxpayers 

about their taxpayer rights and responsibilities under the IRC; and 

5) An organization that operates a program to inform ESL taxpayers about their taxpayer rights and 


responsibilities under the IRC.
 

While IRC § 7526 provides that an organization is eligible to receive a matching grant if it either represents lowincome taxpayers in controversies with the IRS or operates a program to inform ESL taxpayers about their rights 

and responsibility under the IRC, the mission of the LITC Program is best served by requiring all organizations 

interested in receiving a grant under IRC § 7526 to generally provide both services. Organizations that develop 

the capacity to provide both controversy and education services are generally more robust and able to provide 

the most effective service to eligible taxpayers. For example, organizations sometimes assist taxpayers initially 

through outreach and education, and later through representation in a controversy; in these cases, the ability of an 

organization to provide both services not only ensures seamless assistance for taxpayers, but also provides extensive 

protection of taxpayer rights. Thus, the Program Office will only award funds to an organization that is operating 

a program to inform ESL individuals in addition to providing representation to low-income taxpayers. The only 

exception is the new ESL Education Pilot Program started in 2023 and continuing for 2025, under which a grant 

may be awarded to an organization to operate a program to inform ESL taxpayers about their taxpayer rights 

and responsibilities under the IRC without the requirement to also provide tax controversy representation to 

low-income taxpayers. 
LOW INCOME TAXPAYER CLINICS 13 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

AWARD ELIGIBILITY REQUIREMENTS

III. AWARD ELIGIBILITY REQUIREMENTS IV II IV IV

V VI VII I IV

V VI VII VIII

B. REQUIREMENT TO PROVIDE MATCHING FUNDS EQUAL TO AWARD 

IRC § 7526(c)(5) requires clinics to provide matching funds on a dollar-for-dollar basis for all federal funds 

awarded by the IRS. The matching funds requirement ensures that each LITC grant represents a financial 

partnership between the clinic and the federal government for the benefit of low-income and ESL taxpayers. The 

commitment of matching funds by the clinic leverages the federal funding investment so an LITC can assist more 

taxpayers in need. Many programs provide matching funds in cash or third-party in-kind contributions (e.g., 

time worked by volunteers, donated software or office space) that far exceed the minimum required. Only funds 

used in direct support of the LITC Program qualify as matching funds. See Section IV.E.iii, Meeting the Matching 

Funds Requirement. 

C. OTHER ELIGIBILITY REQUIREMENTS 

i. Using Grant Funds to Support Other Activities is Prohibited 

An organization awarded an LITC grant may provide qualifying LITC services within a broader spectrum of 

activity. For example, a clinic may provide representation in nontax matters (e.g., landlord/tenant disputes, 

family law cases) and representation in tax matters, provided LITC grant funds are used only to support the 

representation of eligible taxpayers in a controversy with the IRS and/or a state or local tax agency concerning the 

same or related tax matter. LITC grant funds may also be used for properly allocated portions of indirect costs of 

the organization that support LITC grant activities. 

ii. Charging More Than a Nominal Fee for Services Is Prohibited 

An LITC may not charge more than a nominal fee for its services. If a clinic charges a nominal fee, it must charge 

that same fee to all taxpayers, regardless of the services being sought. The goal of the LITC Program is to enhance 

access to representation, education, and advocacy services for low-income taxpayers. If a clinic charges an amount 

that is not nominal and it results in fewer taxpayers assisted, the goal of the program is not being achieved. A clinic 

may not charge a separate or additional fee (even if it is nominal) to prepare a tax return or a claim for refund. 

NOTE: Reimbursement of actual costs incurred (e.g., photocopying, court costs, and expert witness fees) is not 

considered a fee and is, therefore, permitted. 

iii. Compliance With Federal Tax and Nontax Requirements 

Federal Tax Debts 

The IRS will not award an LITC grant to an applicant noncompliant with a federal tax return filing or payment 

obligation. Consequently, an applicant must be in full compliance with its federal tax responsibilities when 

applying for an LITC grant and throughout the grant year. Standard Form 424, Application for Federal 

Assistance, in Appendix A, requires the applicant to state whether it is delinquent on any federal debt and if so, to 

provide an explanation. The LITC Program Office also conducts reviews to confirm applicants’ compliance with 

federal tax responsibilities and other terms and conditions of the grant. See Section III.C.i, Using Grant Funds to 

Support Other Activities is Prohibited. 
14 LOW INCOME TAXPAYER CLINICS

An outstanding federal tax debt is any unpaid federal tax liability (including penalties and interest) that has 

been assessed, is not disputed, and for which all judicial and administrative remedies have been exhausted or 

have lapsed. An applicant or grant recipient will not be treated as noncompliant for purposes of IRC § 7526 

(and therefore still eligible for funding) if the applicant or grant recipient is in a dispute with the IRS regarding 

a federal tax liability or has entered into and remains current with an installment agreement or other payment 

arrangement with the federal government to satisfy any federal tax liabilities. If you are working with someone at 

the IRS to resolve an outstanding federal tax issue, please provide their name, office in which they work, and their 

phone number when you complete Standard Form 424, question #20. 

IRC § 6103 prohibits the LITC Program Office from disclosing a federal tax compliance issue to anyone who 

is not authorized to receive the taxpayer’s tax information. Therefore, to facilitate the resolution of any potential 

federal tax compliance issues, Form 13424, Low Income Taxpayer Clinic (LITC) Application Information, 

requires applicants to provide contact information for the Tax Compliance Officer (TCO), the individual 

responsible for handling the organization’s federal tax matters. Some applicants are part of a larger organization 

(e.g., an academic institution that operates a clinic), in which case the LITC Program Office must be able to verify 

that the sponsoring organization does not have a federal tax compliance issue before awarding grant funds. The 

TCO must be the person who is the individual responsible for handling the sponsoring organization’s federal tax 

matters. Applicants must also provide documentation (e.g., articles of incorporation or a Form 2848, Power of 

Attorney and Declaration of Representative, signed by the appropriate official) that shows how the individual on 

Form 13424 is properly authorized to receive tax information to prevent the IRS from making an unauthorized 

disclosure. When providing articles of incorporation, ensure it is the most recent version. When providing Form 

2848, be sure of the following: 

n	All required fields are completed; 

n	In section 3, the type(s) of tax are listed (e.g., 940, 941, 1120, 1065, 990); 

n	In section 3, both current and past tax years are listed (e.g., 2024, 2023, 2022, 2021, 2020); 

n	In section 7, the form is signed by an officer of the corporation authorized under the articles of 


incorporation to designate an individual to receive federal tax information for the entity; and
 

n	In Part II, the form is signed by the person being authorized to receive the tax information. 

Complying with federal tax obligations is a requirement to receive an LITC grant, so it is imperative that the 

designated individual be knowledgeable and prepared to promptly address any federal tax issues of the applicant 

or the sponsoring organization. Failure to provide an appropriate contact could delay application processing if 

the LITC Program Office identifies a federal tax compliance issue of the applicant or its sponsoring organization 

and needs to discuss the issue further. In addition, if the LITC Program Office cannot speak with the appropriate 

contact to ascertain the status of the organization’s efforts to address a federal tax compliance issue, no grant funds 

will be awarded to the applicant. Similarly, even after grant funds have been awarded, the LITC Program Office 

performs tax compliance checks throughout the grant year. Without an appropriate contact with whom the LITC 

Program Office can discuss a tax compliance issue, if a tax compliance issue arises during the grant year, the LITC 

Program Office may need to restrict the clinic’s access to grant funds. 
LOW INCOME TAXPAYER CLINICS 15 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

AWARD ELIGIBILITY REQUIREMENTS

III. AWARD ELIGIBILITY REQUIREMENTS IV II IV IV

V VI VII I IV

V VI VII VIII

Federal Nontax Requirements 

The IRS will not award an LITC grant to an applicant that is noncompliant with a federal nontax filing or 

payment obligation. An outstanding federal nontax debt is an unpaid federal liability (other than a federal tax 

obligation) that has been assessed, is not disputed, and for which all administrative and judicial remedies have 

been exhausted or have lapsed. An applicant or grant recipient will not be treated as noncompliant for purposes 

of IRC § 7526 (and therefore still eligible for funding) if the applicant or grant recipient is in a dispute with the 

federal government regarding a federal nontax liability or has entered into and remains current with an installment 

agreement or other payment arrangement with the federal government to satisfy any outstanding federal nontax 

obligations. The LITC Program Office utilizes SAM to help determine whether an applicant or grant recipient is 

eligible to receive payments. See Section III.C.i, Using Grant Funds to Support Other Activities is Prohibited. 

iv. Debarment and Suspension 

When applying for a grant, applicants must make certain certifications and provide certain assurances. One of 

those certifications is the Certification Regarding Debarment, Suspension, and Other Responsibility MattersPrimary Covered Transactions. Applying the “common rule” on non-procurement, debarment, and suspension6 

adopted by the Department of the Treasury at 31 CFR Part 19, Subpart C, an applicant must certify that its 

organization and the clinic’s proposed key personnel are not presently debarred or suspended from covered 

transactions by any federal agency. In addition, an applicant must indicate that within the three-year period before 

applying for a grant, its organization and the clinic’s proposed key personnel have not been convicted of or had 

a civil judgment rendered against them for fraud, theft, or certain other offenses, and have not had one or more 

public transactions terminated for cause or default. An applicant must also indicate that its organization and the 

clinic’s proposed key personnel are not presently criminally or civilly charged with certain offenses. 

Applicants may check the status of the organization and the clinic’s proposed key personnel before applying for a 

grant by searching on www.SAM.gov. If an applicant identifies incorrect information about the organization or 

the clinic’s proposed key personnel, the applicant should contact the agency that reported the information. The 

LITC Program Office utilizes SAM to determine eligibility of grant applicants and prevent improper payments. 

6 The “common rule” means the procedures used by federal agencies to suspend, debar, or exclude individuals or entities from 

participation in nonprocurement transactions under Executive Order 12549. See also Executive Order 12689. 
16 LOW INCOME TAXPAYER CLINICS

i. Determining Type of Application 

ii. Submitting a Full Grant Application on Grants.gov 

IV. APPLICATION AND SUBMISSION PROCESS 

A. ACCESSING THE LITC GRANT APPLICATION PACKAGE AND 

GUIDELINES 

A copy of this publication can be downloaded from www.irs.gov/pub/irs-pdf/p3319.pdf. For information about 

ordering IRS publications, including this one, visit www.irs.gov/forms-pubs/forms-and-publications-by-us-mail or 

call the IRS at 800-829-3676 to place an order. 

Preparing and submitting a grant application is a major undertaking. Take time to understand and review the 

process well before the application submission deadline. Prepare and start the process early. Completing the 

required registrations for the first time is a multi-step process that can take more than eight weeks and MUST be 

completed before the application submission deadline. See Section IV.C.i, System for Award Management, for steps 

that should be taken as early in the application process as possible. If you are notified that your registration may 

not be processed in time, please contact the LITC Program Office as soon as possible to determine what steps to 

take. 

B. REQUIRED CONTENT FOR LITC FULL GRANT APPLICATIONS AND 

NON-COMPETING CONTINUATION REQUESTS 

There are two types of LITC grant applications: LITC Full Grant Applications and NCC Requests. 

n	A new applicant seeking an LITC grant award for the first time, or a returning clinic whose LITC award 

period has ended or will end on December 31, 2024, must submit a Full Grant Application to apply for 

2025 funding. See Section IV.B.ii, Submitting a Full Grant Application on Grants.gov. 

n	A returning clinic funded with a multiyear LITC grant that ends after December 31, 2024, must submit 

an NCC Request to be considered for 2025 funding. See Section IV.B.iv, Submitting a Non-Competing 

Continuation Request on GrantSolutions. 

LITC Full Grant Applications must be submitted electronically via www.Grants.gov. Interested applicants should 

register early and become familiar with www.Grants.gov requirements prior to the due date of the application. 

The submission system on Grants.gov provides free access to the forms required to complete an application and 

notifies applicants if any fields were left blank where a response is required. The Grants.gov website includes a 

narrated tutorial and Frequently Asked Questions to help you use the system. Applicants will receive an email 

confirmation from Grants.gov that serves as acknowledgement of application submission. 

The Funding Opportunity Number for the 2025 LITC Grant Application is TREAS-GRANTS-042025-001. 
LOW INCOME TAXPAYER CLINICS 17 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

iii. Instructions for Completing Full Grant Application 

Appendix A of this publication is a useful guide for completing each of the required application forms. The Office 

of Management and Budget (OMB) requires certain standard forms for all federal grant programs. The IRS also 

requires forms be completed specifically for an LITC grant. To assist applicants in completing the required forms, 

the appendix includes system screen shots, instructions for completing the forms, and examples. 

A complete Full Grant Application consists of these items, submitted through Grants.gov and prepared in 


accordance with the instructions:
 

n	Standard Form 424, Application for Federal Assistance: 

n	Be sure to submit required attachment for item 14 (areas affected by project - counties covered) and 

other attachments as may be needed. 

n	IRS Form 13424, Low Income Taxpayer Clinic (LITC) Application Information; 

n	IRS Form 13424-J, Detailed Budget Worksheet and Narrative Explanations; 

n	IRS Form 13424-M, Low Income Taxpayer Clinic (LITC) Application Narrative: 

n	ESL Education Pilot applicants must self-identify, see I.A. 

n	Attachments Form, which is part of the downloadable PDF from Grants.gov and must be used to submit 

the following items: 

n	Tax-exempt determination letter, if applicable; 

n	Proof of academic accreditation, if applicable; 

n	Most recent audited financial statement (if the applicant expends $1,000,000 or more in federal funds 

during the applicant’s fiscal year, this must be a single audit or program-specific audit as required by 

2 CFR § 200.501). If the applicant’s most recent audited financial statement is available from the 

Federal Audit Clearinghouse (FAC) found at https://harvester.census.gov/facweb/, in lieu of attaching 

the audit, check the “yes” box on Form 13424-M in response to question II.4.ii. See Section IV.E.iv, 

Office of Management and Budget Audit Requirement. 

z	For an applicant that does not have audited financial statements, an unaudited statement for its 

most recent fiscal year and a statement as to why an audited financial statement is not available; 

n	Documentation (e.g., articles of incorporation or an IRS Form 2848, Power of Attorney and Declaration 

of Representative) indicating that the designated TCO on Form 13424 is properly authorized to receive tax 

information; and 

n	Indirect cost rate agreement, if applicable. 

When completing Form 13424-M, LITC Application Narrative, refer to the guidance document 

at www.taxpayeradvocate.irs.gov/about-us/litc-grants/. This document is an especially 

important reference for those applying for an ESL Education Pilot grant. 
18 LOW INCOME TAXPAYER CLINICS

iv. Submitting a Non-Competing Continuation Request 

A returning clinic funded with a multiyear LITC grant that ends after December 31, 2024, must submit an 

NCC Request. All NCC Requests must be submitted via GrantSolutions at www.grantsolutions.gov, the LITC 

program’s web-based grants management system. The submission system on GrantSolutions provides free 

access to the forms required to complete an NCC Request and notifies applicants if any fields were left blank 

where a response is required. NCC Requests will receive an email confirmation from GrantSolutions that serves 

as acknowledgement of the NCC Request submission. Do not submit NCC Requests via Grants.gov. The 

LITC Program Office will provide annual training on how to use GrantSolutions to submit NCC Requests 

and progress reports. Additional questions regarding GrantSolutions may be directed to the Program Office at 

Michael.J.Condict@irs.gov. 

v. Instructions for Completing a Non-Competing Continuation Request 

Appendix A of this publication is a useful guide for completing each of the required forms for an NCC Request. 

OMB requires certain standard forms for all federal grant programs. The IRS also requires forms be completed 

specifically for an LITC grant. To assist applicants in completing the required forms, the appendix includes system 

screen shots, instructions for completing the forms, and examples. 

A complete NCC Request consists of the following items, submitted through GrantSolutions and prepared in 


accordance with the instructions:
 

n	Standard Form 424, Application for Federal Assistance: 

n	Be sure to submit required attachment for item 14 (areas affected by project - counties covered) and 

other attachments as may be needed. 

n	IRS Form 13424, Low Income Taxpayer Clinic (LITC) Application Information; 

n	IRS Form 13424-J, Detailed Budget Worksheet and Narrative Explanations; 

n	Project Abstract, which includes the following information: 

n	Numerical goals for (1) new representation cases to be opened in the calendar year, (2) consultations 

with low-income and ESL taxpayers, (3) educational activities to low-income and ESL taxpayers, and 

(4) low-income and ESL taxpayers reached in educational activities; 

n	Changes to the program plan; 

n	Civil Rights Review responses; and 

n	Statement about availability of the audit on the FAC, if necessary. 

n	Attachments: 

n	Most recent audited financial statement (if the applicant expends $1,000,000 or more in federal funds 

during the applicant’s fiscal year, this must be a single audit or program-specific audit as required by 

2 CFR § 200.501). If the applicant’s most recent audited financial statement is available from the FAC 

found at https://harvester.census.gov/facweb/, in lieu of attaching it, include a statement about its 

availability from the FAC on the Project Abstract. See Section IV.E.iv, OMB Audit Requirement. 
LOW INCOME TAXPAYER CLINICS 19 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

 

z	For an applicant that does not have audited financial statements, an unaudited statement for its 

most recent fiscal year and a statement as to why an audited financial statement is not available; 

n	Documentation (e.g., articles of incorporation or an IRS Form 2848, Power of Attorney and Declaration 

of Representative) indicating that the designated TCO on Form 13424 is properly authorized to receive tax 

information; and 

n	Indirect cost rate agreement, if applicable. 

vi. Withdrawing Applications After Submission 

LITC grant applications may be withdrawn during the application process or prior to when grant money is 

awarded by notifying the LITC Program Office by fax or email. See Section VII.F, Contacting the LITC Program 

Office. Application withdrawals cannot be completed through Grants.gov or GrantSolutions. 

C. SYSTEM FOR AWARD MANAGEMENT REGISTRATION REQUIREMENT 

AND UNIQUE ENTITY IDENTIFIERS 

An organization must be registered with SAM to submit a grant application, and registration requires the 

organization to provide an EIN from the IRS. The SAM registration and renewal process have multiple steps 

and can take four to six weeks to complete. Applicants are advised to register for an EIN and complete the SAM 

registration (or renewal) process well in advance of the application submission deadline. See Avoiding Application 

Common Errors and Missteps When Applying. 

i. System for Award Management 

SAM is a web-enabled government-wide application that collects, validates, stores, and disseminates business 

information about the federal government’s trading partners supporting the contract award, grant, and electronic 

payment processes. SAM registration is necessary to submit a grant application and must be maintained with 

current information while an application for funding is pending and during the performance period of any federal 

award. More information about these processes is available on the SAM website at www.SAM.gov. 

Unless exempted from this requirement under 2 CFR § 25.110, a clinic must maintain current information in 

SAM. This includes information on the clinic’s immediate and highest level owner and subsidiaries and the clinic’s 

predecessors awarded a federal contract or federal financial assistance within the last three years, if applicable, 

until the clinic submits the final financial report required under this federal award or receives the final payment, 

whichever is later. This requires that the clinic review and update the information at least annually after the initial 

registration and more frequently if required by changes in the clinic’s information or another federal award term. 

See Appendix A to 2 CFR Part 25. Individuals registering a new entity and those renewing a registration must 

provide an original, signed notarized letter stating that the individual is the authorized Entity Administrator 

before the registration will be activated or renewed. 

If already registered in SAM, renewal of the registration is required annually. Check when your registration will 

expire and update. You may update as often as you want, but you must update at least once per year. The process 

can take several weeks to complete. 
20 LOW INCOME TAXPAYER CLINICS

i. Due Date for LITC Full Grant Applications and Non-Competing 

Continuation Requests 

ii. Employer Identification Number 

An Employer Identification Number (EIN) is a unique nine-digit number assigned by the IRS to business entities 

operating in the U.S. or U.S. territories for identification and is required to submit an LITC grant application. 

Applicants without an EIN should submit a Form SS-4, Application for Employer Identification Number, to the 

IRS. It can take four weeks for the IRS to assign a number if applying by mail. The fastest way to obtain an EIN is 

online at www.irs.gov/ein. There are options to apply by fax or by mail, but applicants are strongly encouraged to 

use online submission. For more information, search “How to Apply for an EIN” on www.irs.gov. 

iii. Unique Entity Identifier 

Organizations must provide a Unique Entity Identifier (UEI) with the grant application. As of April 4, 2022, the 

UEI replaced the DUNS number, a nine-digit unique entity identifier that was provided by Dun & Bradstreet, 

Inc. The UEI is assigned and managed through SAM. Applicants will no longer have to go to a third-party website 

to obtain an identifier. This change allows the government to streamline the entity identification and validation 

process and lessens administrative burden for entities that want to do business with the federal government. For 

more information about the transition from DUNS to UEI, visit the GSA webpage at www.gsa.gov/about-us/ 

organization/federal-acquisition-service/technology-transformation-services/integrated-award-environment-iae/ 

iae-systems-information-kit/unique-entity-identifier-update. 

iv. Organization Name Change Requests 

All sponsoring organization name changes are processed through SAM. More information is available on the SAM 

website at www.SAM.gov. As a reminder, the LITC Program Office must be kept informed of any changes to the 

sponsoring organization. See Section VI.E.i, Changes in Entity of Sponsoring Organization. 

D. SUBMISSION DUE DATES AND TIMES 

To be considered for 2025 LITC grant funding, grant applications must be submitted by 11:59 p.m. ET on 

June 12, 2024. The time and date of the email confirmation from Grants.gov acknowledging application 

submission serves as evidence that the Full Grant Application was timely submitted and should be retained by 

the applicant. Similarly, the time and date of the email confirmation from GrantSolutions acknowledging the 

submission of the NCC Request serves as evidence that the NCC Request was timely submitted and should be 

retained by the applicant. 

BEST PRACTICE 

Applicants are encouraged to download and maintain a copy of the completed application 

packet. 
LOW INCOME TAXPAYER CLINICS 21 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

ii. Incomplete or Late LITC Full Grant Applications and Non-Competing 

Continuation Requests 

An application is considered incomplete if it fails to include any of the required forms in Section IV.B.iii, 

Instructions for Completing Full Grant Application, or Section IV.B.v, Instructions for Completing NCC Request 

Forms, or if the applicant fails to complete the forms in accordance with the instructions. Incomplete applications 

submitted before the due date will be reviewed and may be considered, depending on the circumstances. 

Applications submitted after the due date will not be reviewed or considered, absent extraordinary circumstances. 

E. BUDGET CONSIDERATIONS AND FUNDING RESTRICTIONS 

i. Spending LITC Grant Funds and Matching Funds 

Grant funds and matching funds must be used for expenses in accordance with the cost principles guidance in 

2 CFR Parts 200 and 1000. Generally, for an expense to be allowable, the expense must: 

n	Be necessary and reasonable for the performance of the federal award and be allocable thereto under the 

applicable cost principles. See 2 CFR § 200.403(a); 

n	Conform to any limitations or exclusions in the cost principles or in the federal award as to types or amount 

of cost items. See 2 CFR § 200.403(b); 

n	Follow policies and procedures that apply uniformly to both federally-financed and other activities of the 

grant recipient. See 2 CFR § 200.403(c); 

n	Be accorded consistent treatment by the grant recipient. A cost may not be assigned to a federal award as 

a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the 

federal award as an indirect cost. See 2 CFR § 200.403(d); 

n	Be determined in accordance with generally accepted accounting principles (GAAP), except for state 

and local governments and Indian tribes only, as otherwise provided for in the cost principles. See 

2 CFR § 200.403(e); 

n	Not be included as a cost or used to meet cost-sharing or matching requirements of any other federallyfinanced program in either the current or a prior period. See 2 CFR § 200.403(f); 

n	Be adequately documented. See 2 CFR § 200.403(g); and 

n	Be incurred during the approved budget period. See 2 CFR § 200.403(h). 

NOTE: In general, grant funds cannot be carried forward from one year to the next unless the LITC Program 

Office approves such carryover. In appropriate circumstances, however, the LITC Program Office may use 

discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget periods 

pursuant to 2 CFR § 200.308(g)(3). 

Clinics should refer to the Uniform Guidance for detailed rules regarding allowable and unallowable expenses. 

Generally, the same rules that apply to expenditures made using federal grant funds apply to expenditures made 

using matching funds. However, IRC § 7526(c)(5) specifically prohibits indirect expenses, including general 
22 LOW INCOME TAXPAYER CLINICS

overhead of the institution sponsoring the clinic, from being counted as matching funds. The Department of 

the Treasury, of which the IRS is a part, adopted the provisions in 2 CFR Part 200,7 unless specific exceptions 

were set forth in 2 CFR § 1000.306, which addresses the valuation rate applicable to controversy representation 

volunteer hours used as match, and 2 CFR § 1000.337, which clarifies that the right to access of records under 

2 CFR § 200.337 does not extend to client information held by authorized LITC practitioners. 

BEST PRACTICE 

Knowledge and understanding of the Uniform Guidance is crucial to properly manage LITC 

grant funds. Several independent vendors provide training on the Uniform Guidance, and it is 

highly recommended for QBAs new to managing federal grant funds to enroll in the training. 

Grant funds may be used to attend such training if the expense conforms to 2 CFR § 200.403. 

Start-Up Expenses May Be Paid Using LITC Grant Funds 

LITC grant funds may be used on start-up activities, and an applicant may be selected to receive an LITC grant 

award for the full grant year even if it anticipates that it cannot begin operations at the start of the performance 

period. All grant recipients must satisfy the statutory matching funds requirement during the period covered 

by the grant and must meet all reporting requirements, regardless of when operations begin. Reports should 

provide information on the status of the start-up activities. In addition, LITC grants to these applicants will 

be conditioned on the performance of required grant activities as detailed in Section I.A, LITC Grant Program 

Priorities, during the immediately succeeding grant year; however, grant funds for the immediately succeeding 

grant year are not guaranteed to be awarded if adequate progress is not made and established milestones not 

timely reached. 

Examples of Allowable Expenses 

Figure 3 lists examples of common expenditures for an LITC. The left-hand column lists items that are an 

allowable use of federal grant funds or matching funds, and the right-hand column lists items that are not an 

allowable use of federal grant funds or matching funds. This is not an all-inclusive list. If clinics have questions 

about whether an expense is allowable, they should consult the Uniform Guidance. If they still have questions, 

they should contact their assigned Advocacy Analyst for guidance before incurring the expense. 

7 See 2 CFR Part 1000. 
LOW INCOME TAXPAYER CLINICS

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

Allowable Expenses Unallowable Expenses 

Reasonable salaries, wages, and fringe benefits 

for services rendered by LITC employees. 

See 2 CFR §§ 200.430(a) and 200.431. 

Purchase, construction, repair, or rehabilitation of 

any building or any portion thereof without prior 

approval. 2 CFR §§ 200.439(b)(1) and 200.439(b)(3). 

Reasonable office supplies and equipment costs 

necessary to provide LITC services. See the general 

rules on allowability at 2 CFR § 200.403. 

Expenses incurred that do not support or benefit the 

LITC Program or which are unnecessary in carrying 

out LITC activities. See 2 CFR § 200.403. 

Rent, utilities, and janitorial services for LITC office 

space. See 2 CFR §§ 200.465 and 200.452. 

Certain advertising and public relations costs. 

See 2 CFR § 200.421. 

Non-alcoholic refreshments for educational 

activities or community outreach events, and for 

volunteers, provided the costs are reasonable. 

See 2 CFR § 200.432. 

Alcoholic beverages. See 2 CFR § 200.423. 

Continuing education courses for employees, if such 

courses will increase their vocational effectiveness 

and is directly related to their work on the LITC grant. 

See 2 CFR § 200.473. 

Refreshments for employees. See 2 CFR § 200.445. 

Pens, mugs, and other small items of memorabilia 

for pro bono representatives working with the clinic, 

provided the cost is reasonable and consistent 

with market prices. See 2 CFR §§ 200.445(a) and 

200.403. 

Professional licensing fees for employees or 

volunteers (e.g., bar association fees for the QTE). 

See 2 CFR § 200.445. 

Printing and publication costs incurred for LITC 

activities. See 2 CFR § 200.461. 

Pens, T-shirts, mugs, or other memorabilia to 

promote LITC services to taxpayers or for the 

personal use of employees. See 2 CFR §§ 200.421(e) 

(3) and 200.445. 

A reasonably proportionate share of the cost of audit 

services. See 2 CFR § 200.425. Lobbyist registration fees. See 2 CFR § 200.75. 

Publicity costs directly associated with the LITC 

Program. See 2 CFR § 200.421. 

Costs of goods or services for personal use 

(as opposed to business use) of LITC staff. 

See 2 CFR § 200.445. 

Installation of telephone lines, including a 

toll-free line, and video conferencing equipment 

necessary to provide LITC services to taxpayers. 

See 2 CFR § 200.471. 

Costs incurred outside the performance period of 

the award, unless specifically excepted by the LITC 

Program Office. See 2 CFR § 200.420. 

Travel performed by LITC staff and volunteers to 

conduct LITC business. See 2 CFR § 200.475. 

Application and other related fees associated with 

entry into the profession for an attorney, CPA, or 

enrolled agent. See 2 CFR § 200.445. 

Travel cost incurred for up to two individuals (or a 

third person if granted an exception by the Director Costs determined using an unreasonable method of 

of the LITC Program) to attend the Annual LITC allocation. See 2 CFR § 200.405(a)(2). 

Grantee Conference. See 2 CFR § 200.475. 

Figure 3, Allowable and Unallowable Expenses 

23 
LOW INCOME TAXPAYER CLINICS

Interpreter services for hearing-impaired or nonEnglish speaking taxpayers. See 2 CFR § 200.459. 

Legal research and reference materials, 

including the IRC and Treasury Regulations. 

See 2 CFR § 200.454(b). 

Indirect costs paid with federal funds. 

See 2 CFR § 200.414. 

Attending American Bar Association (ABA) 

Tax Section meetings and webinars. 

See 2 CFR § 200.473. 

Court costs on behalf of taxpayers if reasonable and 

necessary. See 2 CFR § 200.403(a). 

Malpractice insurance. See 2 CFR § 200.447. 

Case management system software. 

See 2 CFR § 200.453. 

Pre-award costs incurred in anticipation of the 

federal award, where the cost is necessary for 

the performance of the grant. Written approval is 

required. See 2 CFR § 200.458. 

Fundraising costs. See 2 CFR § 200.442. 

Entertainment costs. See 2 CFR § 200.438. 

Fines and penalties. See 2 CFR § 200.441. 

An individual’s membership in a professional 

organization (e.g., the ABA). See 2 CFR §§ 200.454 

and 200.403(b). 

Allowable Expenses Unallowable Expenses 

ii. Direct vs. Indirect Expenses 

Direct expenses are the necessary and reasonable expenses that support LITC activities and the functions of 

the organization. The expenses should be allocated and charged as a direct cost of award funds if it is practical 

to separate the portion of the expense allocable to LITC activities. The determination of whether it is practical 

or reasonable to allocate expenses directly in proportion to use depends on several factors, including the size of 

the organization operating the LITC, the size and number of other functions the organization operates, and the 

amount of the expense. 

Indirect expenses are often commonly referred to as Facilities and Administration (F&A) costs. The Uniform 


Guidance defines indirect costs as:
 

[T]hose costs incurred for a common or joint purpose benefitting more than one cost objective, and 

not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the 

results achieved. 2 CFR § 200.1, Definitions. 

For example, an organization’s $5,000 expense supports LITC activities and two other programs the organization 

operates. Suppose the organization can spend an additional $100 in administrative costs to accurately allocate 

the $5,000 among the three programs in proportion to the benefit each receives. In that case, the allocation is 

reasonable, and the organization should perform the allocation and charge the portion of the $5,000 that is 

allocable to LITC activities as a direct cost. 

24 
LOW INCOME TAXPAYER CLINICS 25 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

Now suppose the organization’s $5,000 expense supports LITC activities and two other programs the organization 

operates, but to properly allocate the $5,000 among the three programs in proportion to the benefit each 

receives, it would cost the organization an additional $2,000 in administrative costs. In that case, direct allocation 

of the cost is not cost-effective, and the organization can account for the $5,000 expense as an indirect cost. 

The organization then apportions the total indirect costs (i.e., the indirect cost pool) to each of the benefiting 

programs using a method that is consistent, reasonable, auditable, and in accordance with generally accepted 

business practices. 

The Uniform Guidance in 2 CFR § 200.414(b) recognizes that because of the diverse characteristics and 

accounting practices of nonprofit organizations, it is not possible to specify the types of costs which may be 

classified as indirect expenses in all situations. The purpose of the federal award is the determining factor in 

distinguishing direct from indirect costs, rather than the nature of the goods and services expensed. 

Typical indirect expenses may include: 

n	Salaries and wages of administrative and support staff; 

n	Related employee benefits; 

n	Facility occupancy costs (e.g., utilities, security, maintenance); 

n	Office supplies; and 

n	Legal and auditing charges. 

Once the organization has classified expenses as either direct or indirect, the organization must determine how 

to allocate the indirect costs among the programs they benefit, so LITC funds do not subsidize the indirect 

costs of other programs or functions of the organization. To calculate the amount of federal funds allocable to 

indirect costs, the organization may use a negotiated ICRA approved by the organization’s cognizant agency. If the 

organization does not have a current negotiated (including provisional) rate, it may elect to charge a de minimis 

rate of 15 percent. 

Indirect costs may not be used to satisfy matching funds obligations. See IRC § 7526(c)(5). 

Negotiated Indirect Cost Rate Agreements and Cognizant Agencies 

Obtaining an ICRA is a complex process that requires preparing and submitting an indirect cost rate proposal 

(including supporting schedules and documentation) and may take several months or even years to establish a 

final rate. A cognizant agency for indirect costs means the federal agency responsible for reviewing, negotiating, 

and approving cost allocation plans or indirect cost proposals developed under 2 CFR Part 200 on behalf of all 

federal agencies. See 2 CFR § 200.1. For Institutions of Higher Education (IHEs), cost negotiation cognizance is 

assigned to HHS or the Department of Defense (DoD) Office of Naval Research, depending on which of the two 

agencies provides more funds to the educational institution for the most recent three years. See 2 CFR Part 200, 

Appendix III of the Uniform Guidance, Indirect (F&A) Costs Identification and Assignment, and Rate 

Determination for Institutions of Higher Education (IHEs), paragraph C,11. 
26 LOW INCOME TAXPAYER CLINICS

For nonprofit organizations, the federal agency that awards the largest dollar value to the organization will be 

designated as the cognizant agency for indirect costs. The federal agency will negotiate and approve the indirect 

cost rates (unless different arrangements are agreed to by the federal agencies concerned) and where necessary, 

negotiate and approve other rates such as fringe benefit and computer charge-out rates. See 2 CFR Part 200, 

Appendix IV, Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit 

Organizations, paragraph C,2,A. If an applicant has no other sources of federal funding and has questions about 

obtaining an ICRA, please contact the LITC Program Office to discuss possible options. 

Organizations that apply an ICRA to determine the portion of indirect costs allocable to a federal award must 

carefully separate direct costs from costs classified as indirect in the ICRA, and the ICRA must set forth cost items 

included in the rate. Indirect costs are then calculated by applying the negotiated rate against the direct cost base. 

Costs accounted for as indirect costs in the ICRA may not be expensed as direct costs (i.e., double-dipping). For 

example, if a clinic is part of a larger organization with an ICRA and the rental cost of the facility in which the 

clinic operates is included in the negotiated rate, the clinic may not include the facilities cost as a direct expense. 

The contractual expense category can be found on Form 13424-L, Statement of Grant Expenditures. 

Provisional Cost Rate Agreement 

If a grant recipient is operating under a provisional ICRA at the commencement of the budget period (also 

referred to as funding period), which ordinarily commences January 1 and concludes December 31 of the same 

calendar year, the provisional rate will be used for billing and reporting purposes for that period. The rate when 

finalized will be applied to future budget periods during which the grant recipient receives funding, if any. 

De Minimis Indirect Cost Rate 

Under 2 CFR § 200.414(f) of the Uniform Guidance, a de minimis rate of 15 percent of Modified Total Direct 

Costs (MTDC) is available for organizations that never had a negotiated ICRA and those that had a negotiated rate 

that has expired. No documentation is required to justify the 15 percent de minimis indirect cost rate. However, if 

the clinic elects to use the de minimis rate to charge indirect costs, it must charge costs consistently across federal 

grants and may not double charge or inconsistently charge as both. 

Modified Total Direct Cost 

MTDC includes all direct salaries and wages, applicable fringe benefits, materials and supplies, services, and travel. 

MTDC excludes equipment, capital expenditures, rental costs, tuition remission, scholarships and fellowships, 

and participant support costs. Other items may only be excluded when necessary to avoid a serious inequity in the 

distribution of indirect costs, and with the approval of the cognizant agency for indirect costs. See 2 CFR § 200.1. 

If a grant recipient charges indirect costs based on an approved ICRA, a copy of the 

agreement must be submitted along with application Form 13424-J, Detailed Budget 

Worksheet and Narrative Explanations. See Section IV.B.ii, Submitting a Full Grant 

Application on Grants.gov. 
LOW INCOME TAXPAYER CLINICS 27 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

iii. Meeting the Matching Funds Requirement 

Grant recipients must provide matching funds on a dollar-for-dollar basis for all federal LITC grant funds 

received. See IRC § 7526(c)(5). In general, the Uniform Guidance provides that all contributions, including cash 

and third-party in-kind, can be accepted as matching funds when such contributions are: 

n	Verifiable from the grant recipient’s records. See 2 CFR § 200.306(b)(1); 

n	Not used as a match or contribution for any other federal award. See 2 CFR § 200.306(b)(2); 

n	Necessary and reasonable for accomplishment of LITC Program objectives. See 2 CFR § 200.306(b)(3); 

n	Allowable under the applicable cost principles. See 2 CFR § 200.306(b)(4); 

n	Not paid by the federal government under another award, except when authorized by federal statute. See 

2 CFR § 200.306(b)(5); 

n	Provided for in the grant recipient’s approved budget. See 2 CFR § 200.306(b)(6); and 

n	In conformity with other applicable provisions of the Uniform Guidance. See 2 CFR § 200.306(b)(7). 

Qualified matching funds can be derived from multiple sources and in various forms, such as cash, services 

provided by volunteers, property, and income from program activities. Third party in-kind contributions, defined 

in 2 CFR § 200.1, means the value of non-cash contributions (i.e., property or services) that (a) benefit a federally 

assisted project or program; and (b) are contributed by non-federal third parties, without charge, to a nonfederal entity under a federal award. Grants may be awarded based on good faith estimates of matching funds, 

including verifiable pledge commitments or other likely sources of funding. However, grant recipients are advised 

to monitor the sources and uses of matching funds throughout the grant year to ensure that sufficient matching 

funds are available to meet the dollar-for-dollar match requirement in IRC § 7526(c)(5). Failure to document the 

sources and amounts of all matching funds may result in the LITC Program Office requiring the grant recipient 

to repay federal funds (plus any applicable interest) received in excess of the documented match. Failure to repay 

the funds within 90 days after the demand results in a debt to the federal government that can be collected by the 

IRS in accordance with 2 CFR § 200.346. 
LOW INCOME TAXPAYER CLINICS

Qualified matching funds include 

(but are not limited to): 

Ineligible matching funds include 

(but are not limited to): 

Legal Services Corporation funds. 

Expenses incurred for the purchase, construction, 

repair, or rehabilitation of any building or any portion 

thereof. 

Salaries, including fringe benefits, of clinic staff. 

Services provided by students that are not furnished 

on a volunteer basis, such as in exchange for 

academic credit. 

Equipment and supplies used in the clinic. Federal work-study funds. 

Other costs necessary to the operation of the 

program. 

Funds from other federal grants unless specifically 

authorized by statute. See 2 CFR § 200.306(b)(5). 

The value of volunteer services furnished by 

professional and technical personnel, consultants, 

and other skilled and unskilled labor. 

Indirect costs, including general overhead of the 

institution sponsoring the LITC. 

The fair market value of donated equipment and 

supplies. 

The fair rental value of donated space. 

Program Income (e.g., nominal fees charged or 

awards of attorney’s fees). See 2 CFR §§ 200.1 and 

200.307 for a definition and discussion of program 

income, respectively. 

 

Figure 4, Qualified and Ineligible Matching Funds 

If an individual on the LITC staff receives an award or fellowship from a non-federal source (e.g., 

the ABA Section of Taxation Public Service Fellowship), the amount of the award may be included 

as matching funds to the extent the award proceeds are used to support LITC activities. 

Valuing Contributions of Goods and Services to Meet the Matching Funds Requirement 

Contributions of goods and services provided to a grant recipient must be valued in accordance with applicable 

cost principles. These principles generally limit values to: 

n	The amount a prudent person would pay for the goods or services in an arm’s length transaction under the 

circumstances prevailing at the time the cost was incurred. See 2 CFR § 200.404(b); or 

n	Fair market value. See 2 CFR § 200.404(c). 

Non-cash contributions (e.g., goods, space, or volunteer services donated to the LITC) from parties other than the 

grant recipient or the federal government (i.e., third-party in-kind contributions) must be valued in accordance 

with the principles stated in 2 CFR § 200.306 (except for contributions of certain volunteer services by a qualified 

representative governed by 2 CFR § 1000.306). 

28 
LOW INCOME TAXPAYER CLINICS 29 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

Determining the Value of Volunteer Services 

The rates used to value volunteer services must be consistent with those paid for similar work in the organization and 

may include a reasonable amount for fringe benefits. If no one else on staff performs similar work that could provide 

a basis for comparative valuation, the organization must use a rate consistent with the labor market rate for similar 

work. One source of wage rates by geographic area can be found on the Bureau of Labor Statistics (BLS) website at 

https://www.bls.gov/bls/blswage.htm. However, BLS data represents a wage rate only, and when used to determine a 

volunteer services valuation rate, it can be adjusted upward by adding a reasonable fringe benefits amount. 

If a third-party employer (e.g., a local law firm’s pro bono campaign) provides one of its employees to work for the 

applicant at no cost, those services are valued at the employee’s regular rate of pay, plus reasonable fringe benefits, 

provided the services are in the same skillset for which the employee is normally paid. If a local law firm offered 

ten hours of volunteer service from an associate attorney in its tax division to an LITC, the LITC could value 

those ten hours at the attorney’s regular rate of pay at the law firm, plus reasonable fringe benefits, provided the 

attorney performs ten hours of substantive legal work. See 2 CFR § 200.306(f). 

Valuation Depends on the Type of Services 

Grant recipients should also be mindful that a volunteer may meet the definition of a qualified representative yet 

may be providing services to the clinic in a non-representative capacity. In the previous example, if the attorney 

spent ten hours repainting the lobby of the LITC over a weekend instead of performing legal work, the LITC 

could still count the volunteer’s time as matching funds; however, it would need to value the attorney’s time at the 

rate for hiring a painter in the local labor market, plus reasonable fringe benefits. 

Services Donated by Employees May Not Be Used as Matching Contributions 

An employee of the grant recipient may not be treated as a volunteer for purposes of valuing in-kind services. 

For example, suppose an LITC pays an employee an hourly wage to work at the LITC three days a week, and 

the employee spends an additional two days each week volunteering at the LITC. In the example, the LITC may 

charge the employee’s wages as an expenditure of federal or matching funds, but it cannot apply the value of the 

two days spent volunteering as a contribution to help meet the matching funds requirement. 

Special Rule for Valuing Volunteer Services of a Qualified Representative 

When the Treasury Department implemented the cost principles of 2 CFR § 200.306, it provided that 

notwithstanding the general rule prescribed in § 200.306(e), LITCs may use the rate found in IRC § 7430 to 

value volunteer in-kind services, if the following conditions are met:8 

n	The grant recipient is funded to provide controversy representation; 

n	Services are provided by a qualified representative, which includes any individual, whether or not an 


attorney, who is authorized to represent taxpayers before the IRS or an applicable court;
 

n	The qualified representative is not a student; and 

n	The qualified representative is acting in a representative capacity and is advocating for a taxpayer. 

8 See 2 CFR § 1000.306. 
30 LOW INCOME TAXPAYER CLINICS

Unless all the above criteria are met, grant recipients should apply the standard cost principles from 

2 CFR § 200.306 as described above. IRC § 7430 provides taxpayers a right to an award of costs and 

fees for services provided by qualified representatives in suits against the United States when the statutory 

requirements of IRC § 7430 are satisfied. The rate at which to value those services is adjusted periodically for 

inflation. For the 2024 calendar year, the maximum rate is $240 per hour, as prescribed in Revenue Procedure 

2023-34, 2023-48 I.R.B. 445, unless the representative can establish that a special factor, as described in 

IRC § 7430(c)(1)(B)(iii), applies. 

The LITC Program Office encourages applicants with questions about how to value volunteer services to contact 

the Program Office for assistance; current grant recipients should contact their assigned Advocacy Analyst. 

BEST PRACTICE 

Utilize various sources of matching funds (e.g., state, local, private, in-kind) when possible to 

ensure financial stability. If any one source is unexpectedly reduced or lost, having different 

sources of match will allow a clinic to look to the other sources of match to make up the 

difference and avoid having to repay federal funds. 

iv. Office of Management and Budget Audit Requirement 

A grant recipient that spends $1,000,000 or more in total federal awards during a fiscal year is subject to the 

audit requirements established by OMB. See 2 CFR § 200.501. Total federal awards received by the organization 

include all sources of federal funding, not just the funds received from the IRS supporting the LITC. The IRS 

may audit expenditures of LITC funds regardless of the dollar amount of federal funding received by the grant 

recipient. 

A grant recipient that expends $1,000,000 or more in federal awards during a fiscal year must provide the IRS 

with a copy of the results of an audit performed in compliance with the Uniform Guidance or post it to the FAC. 

If the most recent audit showed an unfavorable finding, it will not automatically disqualify the grant recipient; 

however, more information may be requested to ensure any deficiencies noted in the audit have been corrected. 

Grant recipients subject to the audit requirement must arrange for an audit by an independent auditor in 

accordance with the Government Auditing Standards developed by the Comptroller General of the United States. 

If an audit is required pursuant to 2 CFR Part 200, it must be organization-wide. The auditor must determine 

whether the organization: 

n	Offers financial statements that present fairly its financial position and the results of its operations in 

accordance with generally accepted accounting principles; 

n	Maintains internal controls sufficient to reasonably assure that the grant recipient is complying with 

applicable laws and regulations, particularly the laws and regulations that could materially impact the 

financial statements; and 
LOW INCOME TAXPAYER CLINICS 31 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS III II V VI VII I V VI VII VIII

n	Complies with laws and regulations that may have a direct and material effect on its financial statement 

amounts and on each major federal program. 

A reasonably proportionate share of the costs of an audit performed in compliance with the Uniform Guidance is 

an allowable LITC grant expense. 

LITC Program Office Cannot Provide Grant Payment History for an Audit 

OMB audits often require historical grant payment information. This information is not 

available from the LITC Program Office. Clinics should direct auditors to the Payment 

Management System (PMS) website at https://pms.psc.gov/grant-recipients/auditconfirmation-procedures.html. This will help avoid the delay that occurs when the LITC 

Program Office has to redirect auditors to the proper source. 
32 LOW INCOME TAXPAYER CLINICS

 

V. APPLICATION REVIEW 

A. TECHNICAL EVALUATION OF FULL GRANT APPLICATIONS AND 

SCORING CRITERIA 

Technical Evaluation 

Full Grant Applications that pass the eligibility screening process will then undergo a technical evaluation by a 

ranking panel. Applications can receive a maximum of 100 points. Applications receiving a score of 49 or lower 

will receive a review by the LITC Program Office to ensure that the ranking score is adequately supported. If the 

score is supported by the content of the application, the application will not move forward in the review process 

and will not receive an award. All applicants may request their scores through a Freedom of Information Act 

(FOIA) request. For information about submitting a FOIA request, see https://www.irs.gov/privacy-disclosure/ 

freedom-of-information-act-foia-guidelines. 

During the technical evaluation, independent ranking panels will review each Full Grant Application using the 

criteria listed below and award points based on the information provided in the application. Ranking panel 

members will evaluate each program plan based on how it will help to accomplish LITC Program goals. Returning 

applicants must adequately answer all the questions, keeping in mind that the ranking panel will not have access 

to any information regarding the applicant’s past performance aside from related information provided in the 

application. Points will be assigned as follows: 

Experience (Maximum 13 points) 

Experience in operating an LITC or delivering representation and education services to low-income and ESL 

taxpayers. 

Financial Responsibility (Maximum 11 points) 

Quality of grant administration and internal accounting procedures. 

Program Performance Plan and Program Coverage (Maximum 76 points) 

Quality of the program plan offered to assist low-income and ESL taxpayers. Evaluation criteria include: 

n	Qualifications, training, and supervision of the clinic staff, students, and volunteers; 

n	Amount of time devoted to the program by clinic staff; 

n	Comprehensiveness of services to be provided; 

n	Procedures for ensuring the confidentiality of taxpayer information; 

n	Procedures for monitoring and evaluating program results; 

n	Publicity and outreach plans; 

n	Organizations identified within the community for collaboration to achieve outreach to the identified 

audience; and 
LOW INCOME TAXPAYER CLINICS 33 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION REVIEW

V. APPLICATION REVIEW I II III IV

Grants Evaluation and Scoring Process

n	Dates and hours of clinic operation. 

n	Number of low-income and ESL taxpayers in the geographic area(s) to be covered, proposed efforts to reach 

these taxpayers, and the number of taxpayers to be assisted. 

Only information contained in the application will be considered during the technical 

evaluation process. Therefore, it is extremely important that a submission contains all 

required information to achieve the maximum score. Applications receiving a score of 49 or 

fewer points during the technical evaluation may not move forward in the review process 

and funding may be denied. See new guidance for assistance completing Form 13424-M at 

www.taxpayeradvocate.irs.gov/about-us/litc-grants/. 

Figure 5, Grants Evaluation and Scoring Process 

Technical 

Evaluation 

Experience Financial Responsibility Program Performance Plan and Program Coverage 

13 11 76

100 points 

B. LITC PROGRAM OFFICE EVALUATION AND SELECTION OF FULL 

GRANT APPLICATIONS AND NON-COMPETING CONTINUATION 

REQUESTS 

i. LITC Program Office Evaluation 

Full Grant Applications that earn a score of 50 points or more during the technical evaluation will undergo a 

secondary evaluation by the LITC Program Office. The secondary evaluation will be based on the information 

contained in the application, and the applicant’s performance history in the LITC Program. The Program Office 

may utilize additional resources to verify information provided in a full application such as an organization’s 

website and accreditation or professional licensure websites. The Program Office will also review and evaluate 

NCC Requests. LITC management officials are subject to recusal if participation in an evaluation would cause a 

conflict of interest or the appearance of a conflict of interest. 

Evaluation of Full Grant Applications 

Information within the application may be subject to verification. The LITC Program Office will consider: 

n	Quality of the proposed program; 

n	History of performance under LITC grants in prior years, if applicable; 
34 LOW INCOME TAXPAYER CLINICS

n	Soundness of the proposed budget; and 

n	Any significant concerns identified during the technical evaluation. 

Evaluation of Non-Competing Continuation Requests 

The LITC Program Office will review all NCC Requests. A risk assessment will be conducted for each applicant 

to determine whether the applicant has responsibly managed federal funds and is likely to continue to do so. 

The proposed budget, any audit findings, and performance history in the LITC Program will be considered in 

assessing the risk of a grant recipient. The performance history includes: 

n	Timeliness, accuracy, and completeness of Interim and Year-End reports; 

n	Any significant concerns identified by the LITC Program Office and how the grant recipient addressed those 

concerns;
 

n	Whether the grant recipient’s past activities match its program plan;
 

n	Whether the grant recipient has a history of not spending all the funds awarded; and
 

n	History of any failure(s) to de-obligate unspent funds promptly.
 

If risks are identified, the NCC Request will receive a full review. As a part of that review, the NTA (unless 

recused) may determine whether conditions or additional monitoring are needed to mitigate the risk or whether 

the NCC Request should be denied. If no serious concerns are identified after a risk assessment is conducted and 

any changes to the proposed program are minor, the NCC Request will be approved. The amount of funding 

awarded will be subject to approval and may be limited by the amount of the Congressional appropriations for 

Grant Year 2025. 

Additional Considerations 

Whether to award grant funds will be based on the technical evaluation (for Full Grant Applications), the LITC 

Program Office evaluation, and the following additional considerations: 

n	Existence of other clinics in the applicant’s geographic coverage area assisting the same population of 

taxpayers; 

n	Scope of services that the clinic will provide; 

n	The number of low-income and ESL taxpayers who will be assisted; 

n	Languages in which assistance will be provided to taxpayers; 

n	Reasonableness of funds sought for the quantity and quality of services to be offered; 

n	Other sources of funding available to the clinic; 

n	The sources of matching funds that the clinic plans to use; 

n	Anticipated funding available to the LITC Program Office for grant awards; and 

n	Any non-compliance with all federal tax and nontax obligations, and national policy requirements. See 

Section III.C.iii, Compliance with Federal Tax and Nontax Requirements. 
LOW INCOME TAXPAYER CLINICS 35 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

APPLICATION REVIEW

V. APPLICATION REVIEW I II III IV

 

For organizations that are requesting federal funds to provide representation by referring taxpayers to qualified 


representatives, award decisions will also consider the following:
 

n	The qualifications of the representatives who have agreed to accept pro bono case referrals from the LITC; 

and 

n	The ability of the organization to monitor case referrals and ensure that the pro bono representatives are 

handling the cases properly, including taking timely case actions and ensuring services are offered for free. 

Academic clinics that carry the additional responsibility of teaching and mentoring students may represent fewer 

taxpayers than non-academic clinics; however, academic clinics can accomplish LITC Program goals in a variety of 

additional ways, such as: 

n	Providing technical assistance; 

n	Training and mentoring other LITCs; 

n	Publishing articles about the LITC Program or on tax topics that impact low-income and ESL taxpayers; 

n	Commenting on proposed Treasury regulations that affect low-income or ESL taxpayers; and 

n	Mentoring graduates and encouraging them to perform pro bono work on behalf of low-income and ESL 

taxpayers. 

Final Funding Decision 

Final funding decisions are made by the National Taxpayer Advocate, unless recused due to a potential or actual 

conflict of interest with an applicant. In recusal situations, the final funding decisions are made by the Deputy 

National Taxpayer Advocate. 

ii. Civil Rights Compliance Reviews 

All Full Grant Applications receiving a ranking panel score of 50 points or higher and all NCC Requests undergo 

a civil rights compliance review by the IRS Office of Equity, Diversity and Inclusion (EDI), Civil Rights Unit 

(CRU) to ensure compliance with civil rights laws. Department of Justice regulations state that all federal agency 

staff determinations of civil rights compliance shall be made by, or be subject to review by, the agency’s civil rights 

office. In addition, a Department of the Treasury grant recipient must maintain records, provide information, 

and afford Treasury access to records to the extent Treasury finds it necessary to determine whether the recipient is 

compliant with civil rights laws and regulations. For details about the various civil rights laws applicable to federal 

grant recipients, see Section VI.D.i, General Compliance. 

The CRU will review all grant applications meeting the above-referenced criteria. To the extent necessary to make 

a civil rights compliance determination, the CRU or LITC Program Office may request that an applicant provide 

additional information that is readily available or can be compiled in a reasonable manner. Examples of such data 

and information include, but are not limited to: 

n	The manner in which services are or will be provided by the program, and related data necessary 


for determining whether any persons are or will be denied such services on the basis of prohibited 


discrimination;
 
36 LOW INCOME TAXPAYER CLINICS

n	The population eligible to be assisted by race, color, national origin, age, sex, or disability; 

n	Data regarding covered employment, including use or planned use of bilingual public contact employees 

serving beneficiaries of the program, where necessary to permit effective participation by beneficiaries with 

limited English proficiency; 

n	The location of existing or proposed facilities connected with the program, and related information adequate 

for determining whether the location has or will have the effect of unnecessarily denying access to any 

persons based on prohibited discrimination; 

n	The present or proposed membership, by race, color, national origin, sex, age, or disability, in any planning 

or advisory body that is an integral part of the program; and 

n	Data such as demographic maps of the racial composition of affected neighborhoods or census data. 

Upon completion of the application reviews, the CRU will forward to the LITC Program Office a preliminary 

civil rights determination based on the information in the Full Grant Application, NCC Request, and any other 

information the CRU received from the grant recipient. If an applicant has provided incomplete information, 

the Program Office may request additional information from the applicant and provide it to the CRU. No LITC 

grant funding may be awarded until the CRU has made its final determination. 

The CRU annually conducts selected post-award reviews to ensure civil rights requirements are in place and to 

provide technical assistance. The CRU will contact grant recipients directly to schedule the reviews. The following 

are examples of civil rights compliance items addressed during post-award reviews: 

n	External building accessibility (e.g., accessible entrances, curb cuts, and sufficient parking spaces for persons 

with disabilities); 

n	Interior accessibility (e.g., signage for emergency routes, routes to and within the service area, sufficient 

seating in the service area, restrooms, water fountains, and elevators); 

n	Non-discrimination policies (e.g., Publication 4053, Your Civil Rights Are Protected, displayed in service 

areas, and the organization’s non-discrimination policy posted and disseminated in marketing materials); 

n	Accommodations for persons with disabilities (e.g., sign language interpreters and Braille/large print 


documents); and
 

n	Accommodations for persons with limited English proficiency (e.g., bilingual volunteers, language 


interpreters/language line, and community resources).
 

The results from the selected post-award reviews are compiled into a report and provided to the LITC Program 

Office. 

Contacting the Civil Rights Unit 

For additional information on civil rights requirements, see Publication 4454, Your Civil Rights Are Protected, or 

contact the CRU at edi.civil.rights.division@irs.gov. 
LOW INCOME TAXPAYER CLINICS 37 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX VI. AWARD ADMINISTRATION VI VII I II III IV

V VII VIII

VI. AWARD ADMINISTRATION 

A. NOTIFICATION OF SELECTION 

The LITC Program Office will notify all applicants by October 2024 about whether they have been selected 

to receive a 2025 grant award. Selected applicants will be notified by phone and email. If Congress has passed 

final appropriations legislation for the 2025 fiscal year by November 2024, notification of selection will include 

the amount of the award. If Congress has not passed final appropriations legislation for the 2025 fiscal year by 

November 2024, notification of selection may not include the total amount of the award or may only include 

an approximate amount. In that case, the Program Office will provide the total award amount in a subsequent 

communication. 

After notification of selection, the Program Office will invite the Clinic Director and Qualified Business 

Administrator of first-time LITC grant recipients to a mandatory welcome webinar. All grant recipients will be 

required to attend the Annual LITC Grantee Conference, unless excused. See Section VI.C.iii, Annual LITC 

Grantee Conference. Applicants not selected to receive an award will be notified through GrantSolutions. 

B. NOTICE OF AWARD 

The LITC Program Office will issue an NOA to each applicant selected to receive funding for the grant year, 

containing the information required by 2 CFR § 200.211. If Congress has not passed final appropriations 

legislation and the federal government is operating under a Continuing Resolution at the start of the grant 

year, the Program Office may issue subsequent NOAs, each providing a partial award amount, until a final 

appropriation is enacted. 

The NOA will provide the amount of funding awarded to the grant recipient, whether the full or a partial grant 

year amount, the grant period, and the terms and conditions of the award. In addition, the NOA incorporates 

by reference the requirements specified in this publication and lists any additional conditions of the award, if 

applicable. 

All funding will be based on the availability of annually appropriated funds. If more funds become available 

during the grant year, the Program Office may award additional funds to well-performing clinics not receiving 

maximum funding accompanied by a new NOA with the revised award amount. The total award amount may not 

exceed $200,000 for the grant year, unless otherwise legislated by Congress. Requests for additional funds must be 

made in writing and timely submitted with the interim progress report in order to be considered. All grant funds 

will be obligated no later than September 30 of each grant year. 
38 LOW INCOME TAXPAYER CLINICS

C. ADMINISTRATIVE REQUIREMENTS 

i. Standards for Operating a Low Income Taxpayer Clinic 

This publication provides baseline standards of operation for organizations funded with an LITC grant. The 

standards ensure that all LITCs provide consistent and quality service to low-income and ESL taxpayers. 

LITCs are required to fill the following key staff positions: 

Qualified Tax Expert (QTE) is, generally, a staff member of the clinic (or a volunteer in the case of the ESL 

Education Pilot Program). The QTE must have sufficient tax law expertise to oversee technical, substantive, and 

procedural tax matters. The QTE must be an attorney, CPA, or EA who is currently authorized to practice before 

the IRS and provide representation on behalf of low-income taxpayers in disputes with the IRS. The QTE is also 

responsible for reviewing all educational materials for accuracy before distribution. 

Qualified Business Administrator (QBA) is a staff member with sufficient business administration expertise to 

oversee the clinic’s business operations. If a department fulfills this requirement, as opposed to a single individual, 

please provide details in the application about the staff member who oversees the department. The QBA must 

demonstrate education or experience with business or program administration, such as internal controls, grant 

funds management, budgeting, procurement, or the equivalent. A grantee may outsource part of its accounting 

function, but a staff member must still be designated as the QBA. 

Clinic Director is a staff member with overall management responsibility for the clinic. The Clinic Director 

may also be the QTE or QBA, if qualified. The Clinic Director manages day-to-day clinic operations, prepares 

or reviews the required clinic reports, and may sign reports as the clinic’s authorized representative. The Clinic 

Director serves as the primary contact person for both the LITC Program Office and the Local Taxpayer Advocate 

Office. The Clinic Director must be able to promptly respond to LITC Program Office inquiries and should have 

a thorough knowledge and understanding of the LITC’s operations. 

As a general rule, all key personnel must be employees of the sponsoring organization. Using independent 

contractors or volunteers to fill key positions must receive advance approval in writing from the LITC Program 

Office. Utilizing volunteers or independent contractors to fill key staffing positions may be permitted in limited 

circumstances but only as a temporary measure. The Program Office will work closely with the organization to 

develop a timeline for filling the position with a paid employee of the organization. 

Access to Representation in the U.S. Tax Court and Other Federal Courts 

All LITCs providing representation services must have a staff member or a pro bono panel member who is 

admitted to practice before the U.S. Tax Court and other federal courts to represent taxpayers in litigation matters. 

The Clinic Director and the QTE must not be under suspension or disbarment from practice before the IRS and 

must be in good standing with all relevant professional state licensing authorities and federal courts. The Program 

Office will seek confirmation of the status of these individuals before awarding any grant funds. 
LOW INCOME TAXPAYER CLINICS 39 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

AWARD ADMINISTRATION

VI. AWARD ADMINISTRATION I II III IV

V

Maintaining a Physical Location

 LITCs must maintain a physical place of business and a permanent address. A physical place of business means 

a permanent office space where clients can be received and files are kept. Telephones must be answered during 

business hours; however, the telephone need not be answered at the same location as the physical place of 

business. 

If an applicant proposes to utilize workshare space as a physical place of business, the workshare space must satisfy 

the following criteria: 

n	The clinic must be able to identify it as the clinic’s place of business in letterhead and correspondence. 

n	The clinic must have access to a private office and private meeting space to enable confidential conduct of 

business. 

n	Taxpayer records or information may only be received and stored at the location if the individual receiving 

the information has been trained to maintain confidentiality and security. 

n	Maintaining confidentiality and security requires that information received must be kept in a secure 

location, access must be limited to only those who have a need to access, and those receiving information 

agree to hold the information in confidence. 

Applicants with only a virtual office will not be awarded LITC grant funds. 

Providing a Toll-Free Number 

To increase access to low-cost representation, grant recipients are encouraged to provide a toll-free telephone 

number. Grant funds may be used to pay for a toll-free number. See 2 CFR § 200.471. 

Training Staff and Volunteers 

LITCs must provide training to clinic staff, volunteers, and other program participants (such as fellows and 

interns) to increase the knowledge and skills necessary to effectively deliver tax representation, education, and 

advocacy services. Clinic Directors must ensure that the LITC staff, volunteers, and other program participants 

receive training based on their knowledge, skills, and experience, and the needs of the taxpayers they will assist. 

Clinic Directors are encouraged to develop a training plan for all program participants who provide services to 

taxpayers. Besides substantive technical and legal training, clinics should provide staff training regarding grant 

requirements such as determining the amount in controversy and the 90/250 requirement. 

As part of a comprehensive training plan, the Program Office encourages clinic staff and volunteers to attend 

continuing professional education programs sponsored by the IRS and professional organizations with expertise in 

tax controversy resolution. Grant recipients may use grant funds to attend such programs if the subject matter is 

necessary for the performance of the grant and the cost is reasonable. See 2 CFR §§ 200.403(a) and 200.473. 

Clinics are also encouraged to conduct Continuing Legal Education (CLE) or Continuing Professional Education 

(CPE) trainings for staff and volunteers. Clinics should track all CLE and CPE related trainings offered for credit. 

CLEs and CPEs sponsored by the clinic will be reported on progress reporting Form 13424-A, LITC General 

Information Report, under the “Professional Education Activities” section. The details of all other trainings 

provided by the clinic that are not for credit or are attended by staff and provided by other sponsors will be 

reported on Form 13424-N, LITC Program Narrative Report. 
40 LOW INCOME TAXPAYER CLINICS

Maintaining Access to Tax Research Materials 

LITCs must have convenient access to an adequate tax library and research materials, including the current 

version of the IRC and related Treasury Regulations in hard copy or electronic format. Access to research materials 

may be through online resources. Grant recipients may use grant funds to acquire tax research materials. See 

2 CFR § 200.454(b). 

ii. Low Income Taxpayer Clinic Program Office Webinars 

Unless otherwise noted below, the Program Office will announce webinars on the LITC Toolkit. The Toolkit is 

the main way that the LITC Program Office communicates with clinics. The password-protected site is accessible 

to all those involved with the clinic, including staff, students, and volunteers. The password is provided to all 

funded clinics and can be obtained any time during the grant year from a clinic’s assigned Advocacy Analyst. The 

password is changed annually, and all clinics will be notified about the new password when it is updated. Some 

webinars may be geared to specific individuals in the organization responsible for performing the certain activity 

highlighted in the webinar. The Program Office encourages participation in the webinars and information sharing 

about the webinars with the appropriate individual(s) associated with the clinic. 

Application Webinars 

The LITC Program Office generally conducts a yearly webinar to provide potential applicants with information 

about the application requirements and process. The intended audience for the webinar includes applicants 

proposing to start an LITC or expand the work of existing clinical programs. The webinar for applicants 

applying for a grant for 2025 will be held on April 25 and May 7, 2024, from 1:00 to 2:30 p.m. ET. Details and 

registration information will be available at www.irs.gov/litc. Another webinar will be presented to returning grant 

recipients on May 9, 2024, from 1:00 to 3:00 p.m. ET and will focus on changes to the application process and 

how to submit an NCC Request. This webinar will be announced on the LITC Toolkit. An application Q&A 

webinar for all applicants will be held on June 5, 2024, from 1:00 to 2:00 p.m. ET. Details about this session will 

be provided on www.irs.gov/litc and the LITC Toolkit. 

Administrative and Technical Topic Webinars 

The LITC Program Office also conducts and coordinates webinars to provide information on general grant topics, 

such as requirements for completing grant applications and reports, legal issues impacting low-income taxpayers, 

and substantive topics that will help clinicians advocate for taxpayers. The Program Office will also announce 

webinars on tax-related topics sponsored by other organizations such as the IRS and the ABA Section of Taxation. 

All webinar announcements will be made through the LITC Toolkit. Although the LITC Program Office will 

provide information about webinars sponsored by other programs or organizations, the Program Office does not 

endorse the webinar sponsors or any materials distributed during such webinars. An LITC’s decision whether 

or not to participate in such webinars will not result in the Program Office giving any preferential or negative 

treatment to the LITC. The Program Office is merely informing LITCs of training opportunities that may be of 

interest to clinicians. 
LOW INCOME TAXPAYER CLINICS 41 

I. LITC PROGRAM DESCRIPTION II III IV

V VI VII VIII APPENDICES GLOSSARY INDEX

AWARD ADMINISTRATION

VI. AWARD ADMINISTRATION I II III IV

V

iii. Annual Low Income Taxpayer Clinic Grantee Conference 

Applicants notified they have been selected to receive a 2025 grant award must attend the Annual LITC Grantee 

Conference, which will be held in December 2024. Generally, the Clinic Director and the QTE must attend the 

conference in its entirety unless the Director of the LITC Program has excused them in writing from attending 

all or part of the conference. The Program Office will provide the dates and location of the conference when 

notifying applicants that they have been selected for an award if the details are known at that time. Information 

about the conference will also be provided on the LITC Toolkit. 

Cost of Attendance 

The cost of attending the conference (e.g., transportation, hotel, and meals) can be paid with grant funds (or 

can qualify as matching funds if travel expenses are paid using non-federal funds) and should be included in an 

applicant’s budget. For more information, see Section IV.E.i, Spending Low Income Taxpayer Clinic Grant Funds 

and Matching Funds. LITC grant funds or matching funds may not be used to pay the cost of more than two 

conference attendees. However, an LITC may request an exception to this policy in special circumstances. For 

example, a clinic is planning to send the QTE and Clinic Director to the conference, but a new staff attorney 

was recently hired and will devote a significant amount of time representing low-income taxpayers. Since the 

third person will be doing controversy work and the conference provides an economical and beneficial means of 

providing substantive tax controversy education, the Director of the LITC Program may approve the use of LITC 

grant funds to cover all or a portion of the cost for attendance of the third person. 

More Than Two Conference Attendees 

If a grant recipient wishes to send more than two staff members to the conference, a written request must be 

submitted to the Director of the LITC Program within two weeks before the start of the conference. The Director 

or her designee will grant approval to timely submitted requests for additional registrants if space is available. 

If the grant recipient wishes to seek a special exception to use LITC direct or matching funds to send a third 

individual to the conference, the clinic should explain the special circumstances that support an exception and the 

costs associated with sending a third person. The Director of the LITC Program has the discretion to allow the 

clinic to use grant funds for all or a portion of the costs to send a third individual. Without an exception or if an 

exception is denied, any conference expenses (e.g., transportation, hotel, and meals) of additional attendees are the 

responsibility of the grant recipient and must not be paid using federal or matching grant funds. 

Requesting to Be Excused From Attendance 

If the Clinic Director or QTE cannot attend all or part of the conference, a request for an exception must 

be submitted in writing within two weeks before the start of the conference. The request should identify the 

critical reason for the exception request, and the name, title, and duties of any other person who will attend the 

conference on behalf of the grant recipient. 

All requests for exceptions related to the conference as detailed above should be addressed to the Director of the 

LITC Program and sent to the clinic’s assigned Advocacy Analyst. The best way to send exceptions is via email 

or e-fax; see Section VII.F, Contacting the Low Income Taxpayer Clinic Program Office. Instructions for submitting 

exception requests can also be found on the LITC Toolkit under Clinic Training → LITC Grantee Conference. 
42 LOW INCOME TAXPAYER CLINICS

iv. Developing a Community Outreach Plan 

LITCs should develop an outreach plan to publicize the clinic and its services to low-income and ESL taxpayers. 

LITCs should also advertise and promote themselves as providing representation and education on behalf of 

low-income and ESL taxpayers. Outreach activities may involve direct communication with taxpayers or be 

accomplished through contacts with other organizations or community groups that assist low-income and ESL 

taxpayers. LITCs are encouraged to identify linguistic populations, geographic service areas, or other segments of 

the low-income taxpayer community in which to focus outreach efforts. 

Publicizing Low Income Taxpayer Clinic Services 

LITCs may use a variety of means to publicize their services, including brochures, flyers, placards and posters, 

newspaper listings, public service announcements on radio and television, websites, and social media. LITCs 

should also publicize their program through their organization’s website and community partners. In promoting 

a clinic on a larger organization’s website, consider the taxpayer’s experience and how the taxpayer can most easily 

locate information about the clinic and its services. To reach ESL taxpayers, LITCs should produce publicity 

materials not only in English but also in other languages commonly spoken by taxpayers in their geographic area. 

Publicity materials and announcements to advertise LITC services must focus on core services: 

n	Representation in controversy cases; 

n	Consultations about tax matters; 

n	Education about taxpayer rights and responsibilities; and 

n	Advocacy efforts to resolve systemic tax issues that affect low-income and ESL taxpayers. 

Grant recipients are encouraged to publicize their program through their organization’s 

website, social networking platforms, and community partners. 

Publicity materials may not advertise tax return preparation services or Individual Taxpayer Identification Number 

(ITIN) application preparation assistance. LITCs may prepare tax returns and ITIN applications only in two 

limited contexts. See Section VI.C.xv, Preparing Tax Returns and Individual Taxpayer Identification Number 

Applications. 

LITCs must include a message on their website and in all publicity materials and 

announcements stating that the clinic does not generally provide tax return preparation. 
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Brochures, flyers, or other clinic information that may be distributed in IRS offices or at joint outreach events 

with IRS functions should contain language to indicate that a taxpayer’s decision to obtain representation from 

an LITC will not result in the IRS giving preferential treatment in handling the dispute or problem and will not 

affect the taxpayer’s rights before the IRS. 

Such disclaimers need not be worded exactly as above but must convey this principle. In addition, clinics may 

not use the IRS or TAS logos in any advertising materials. Clinics are strongly encouraged to use the LITC logo 

in all newly-printed or published materials and also on their websites. High-quality electronic files of the logo are 

available on the LITC Toolkit. The logo should not be altered. 

With the passage of the Taxpayer First Act, Section 1402,9 IRS employees can refer a taxpayer to a specific 

LITC for assistance without violating the applicable ethical standards of conduct. Before the change in law, IRS 

employees were prohibited from referring a taxpayer to a particular LITC practitioner or a specific LITC for 

assistance with an IRS issue. All IRS Taxpayer Assistance Center (TAC) locations are annually provided with 

copies of Publication 4134, Low Income Taxpayer Clinic List, to facilitate these referrals. In addition, Section 

1401 of the Taxpayer First Act promotes collaboration between LITCs and Volunteer Income Tax Assistance 

(VITA) grant recipients by encouraging VITA grant recipients to advise taxpayers about the availability of LITCs, 

the eligibility requirements for assistance, and the locations and contact information for the clinics. 

Identifying Effective Outreach Strategies 

To enhance efficiency and identify effective strategies, LITCs are encouraged to implement a process that tracks 

how taxpayers seeking services learned about the clinic and the services offered. For example, this information 

could be obtained on the intake or screening form completed by low-income taxpayers seeking representation 

or advice. For educational activities, the clinic could request that attendees indicate on a sign-in sheet how they 

learned about the event. The Program Office may ask for information as to how taxpayers hear about the clinics 

to share information with the IRS about which forms, publications, and notices are most effective at driving 

taxpayers to seek LITC assistance. 

v. Building Community Partnerships 

LITCs should develop and maintain relationships with other community-based organizations that assist lowincome and ESL individuals. Community-based organizations might include local social service agencies such as 

human services, workforce development, or refugee resettlement; community action programs providing heating 

assistance or head start programming; schools, community colleges, religious organizations, domestic violence 

shelters, and senior meal sites. 

Effective community partnerships help LITCs to enhance visibility in the community, access taxpayers in insular 

hard-to-reach communities, better understand nontax issues that affect low-income individuals and families, 

and establish a framework for mutual referrals of taxpayers needing services. Clinics should also network with 

individuals and groups within the clinic’s sponsoring organization to share information about the LITC Program 

to promote cross referrals of cases and to collaborate on educational activities and outreach opportunities. 

9 Pub. L. No. 116-25, § 1402, 133 Stat. 981, 997 (July 1, 2019). 
44 LOW INCOME TAXPAYER CLINICS

 

BEST PRACTICE 

Establish a regular schedule for providing clinic updates to the staff within the clinic’s 

sponsoring organization. For example, provide presentations about clinic activities at monthly 

staff meetings or distribute a quarterly newsletter to colleagues highlighting clinic success 

stories and impactful outreach and educational events. These regular communications will help 

staff to remember to identify tax issues in their cases and refer to the clinic when needed. 

vi. Networking With Other Low Income Taxpayer Clinics 

LITCs are encouraged to maintain an active network with other clinics. Networks provide an opportunity for 

clinics to collaborate on tax issues that affect low-income and ESL taxpayers, discuss case strategies, share ideas on 

education and outreach, and share training on tax practice and procedures. Clinics are encouraged to submit best 

practices developed through networking to the LITC Program Office, so they can be shared with other clinics to 

improve the overall quality of the LITC Program. 

vii. Mentoring 

The LITC Program Office encourages experienced grant recipients to become mentors to provide guidance and 

technical assistance to other LITCs. The LITC Program Office may ask experienced LITC clinicians to consider 

mentoring less experienced clinicians. That assistance may include recommendations for developing processes, 

procedures, or policies; providing samples of substantive education materials for clinic staff or taxpayers; helping 

develop outreach or education plans; and providing suggestions or other feedback on casework. 

viii. Technical Assistance Consultation 

A technical assistance consultation is a discussion with a tax practitioner or other service provider designed to 

provide brief advice about a federal tax issue. This assistance could be provided to an LITC clinician from another 

program, a member of the private bar, a colleague, or a local VITA site member. However, if advice is given to a 

member of the clinician’s sponsoring or co-located organization to provide to a client about a specific tax issue, it 

is more properly counted as a taxpayer consultation, not a technical consultation. Grant recipients must report the 

number of technical assistance consultations provided on Form 13424-A, Low Income Taxpayer Clinic (LITC) 

General Information Report. 

ix. Maintaining Client Confidentiality 

Avoiding Unauthorized Disclosure 

Tax professionals have ethical requirements to maintain client confidentiality. See, for example, ABA Model Rule 

of Professional Responsibility 1.6 and IRC § 7525. LITC employees and volunteers generally must not disclose 

information relating to the representation of a client to third parties unless the client gives informed consent. The 

confidential nature of each taxpayer’s information must always be respected, and each employee and volunteer 
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must safeguard taxpayer information against inadvertent or unauthorized disclosure. Thus, it is critical for an 

LITC to maintain information security and limit access to taxpayer information to those who need to know. 

Treasury Regulations under IRC § 7216 generally prohibit a grant recipient, its employees, and its volunteers from 

disclosing or using a taxpayer’s return information except when the tax return preparer has obtained prior written 

consent from the taxpayer in a manner that complies with the procedures in the regulations and other guidance 

issued by the IRS. See 26 CFR § 301.7216-2. The regulations authorize disclosure or use without consent only in 

very limited situations, such as pursuant to an order of a court or a federal or state agency, or for preparation or 

audit of state or local tax returns. For unauthorized disclosure or use, IRC § 7216 imposes a sanction of up to one 

year in prison or a $1,000 fine, or both, plus the costs of prosecution. In addition, the penalty under IRC § 7216 

increases to $100,000 in the case of disclosures or uses in connection with taxpayer identity theft. IRC § 6713 

imposes a civil penalty of $250 for each disclosure or use, up to $10,000 per calendar year (penalty of $1,000 per 

disclosure or use if related to identity theft up to $50,000 per calendar year). 

Client Information Must Be Redacted From Training Materials 

Client information must be redacted from materials before being used for training. This includes deletion of 

names, addresses, taxpayer identification numbers, and any other information that could reasonably lead to 

identification of the client. It is also suggested that if using a taxpayer’s situation as an example or case study in the 

training, the material facts be sufficiently changed to prevent identification of the taxpayer. The LITC Program 

Office takes protection of taxpayer information seriously, and thus any materials submitted for use during the 

LITC Grantee Conference must comply with IRS rules for training presentations that explore taxpayer factual 

scenarios – namely that all taxpayer identifying information and tax data used in course materials must be entirely 

fictional. IRM 11.3, Disclosure of Official Information, contains instructions, guidelines, and procedures to 

protect the confidentiality of returns and return information. 

Sharing Information With the Media 

Generally, confidentiality requirements and disclosure restrictions prohibit clinic personnel from providing details 

about any taxpayer represented by the clinic in response to requests from the media. News reporters and other 

members of the media do not have a need to know taxpayer information. The LITC must obtain a written waiver 

from the taxpayer before disclosing any of the taxpayer’s information and be sure the taxpayer fully understands 

the potential ramifications that could result from disclosing the information, even if the taxpayer is the person 

requesting that the LITC speak to a member of the media. If the client chooses to share information with the 

media, suggest to the client that he or she make it a condition of the interview that the story be produced without 

photos and names. 

Media coverage can create a conflict of interest between the LITC and a client. An article that describes the client’s 

situation and mentions the clinic’s services may benefit the clinic by providing outreach; however, the clinic must 

consider any potential negative repercussions that publicity may have on the taxpayer. For example, the taxpayer 

could be dealing with other nontax issues (e.g., custody or child support conflicts, other creditors, immigration) 

that could be negatively impacted by the media coverage. LITCs should clearly communicate to clients that they 

are under no obligation to share any personal information with the media. 
46 LOW INCOME TAXPAYER CLINICS

x. Recruiting and Supervising Volunteers 

Creating Written Position Descriptions for Volunteers 

LITCs are encouraged to create written position descriptions for volunteers and outline the qualifications for 

each position, such as whether the volunteer can act as an authorized representative, training and experience, 

educational background, language skills, and other qualifications relevant to providing representation, education, 

and advocacy on behalf of low-income and ESL taxpayers. 

Establishing and Maintaining a Pro Bono Panel 

LITCs are encouraged to offer additional taxpayer assistance by recruiting qualified representatives who agree to 

serve on a pro bono panel, accept cases from the LITC, and represent LITC clients at no cost. Pro bono volunteers 

may also be recruited for other clinic tasks, depending on their experience and background, such as presenting at 

educational activities, conducting outreach, or supervising students. Clinics may utilize volunteers made available 

through national, state, or local bar associations; societies of accountants; and enrolled agent networks. 

Monitoring Referrals to Low Income Taxpayer Clinic Volunteers 

LITCs must have a system to monitor referrals and ensure that pro bono representatives are handling cases 

properly, including taking timely case actions and providing services for free. Ongoing monitoring is not required 

if referring a case to another LITC. Pro bono representatives may not charge a fee for services (other than asking 

for reimbursement of expenses such as photocopying and court filing fees). 

Referrals May Only Be Made to Qualified Representatives 

LITCs may only refer cases to pro bono volunteers for representation if the volunteer is authorized to practice 


before the IRS or the court where the IRS controversy will be adjudicated.
 

Representation Through Referral 

An LITC can meet the requirement to provide representation by referring qualified taxpayers to a qualified 

representative. The representative must agree to provide representation free of charge. One goal in expanding 

qualifying activities to allow an LITC to refer the majority of or all cases to a qualified representative is to expand 

access to unserved taxpayers or underserved areas of the country. These types of LITCs can also help to ensure that 

the resources of current LITCs are maximized. To the extent that these programs are contacted by taxpayers from 

a locality where existing LITC(s) operate, the program should determine whether a local LITC is able to take 

the case. 

Referrals After Declining a Case 

Generally, no person associated with the LITC should provide representation in a case the clinic declined. 

Additionally, employees and volunteers of the LITC may not provide representation for a fee to a client of the 

LITC in a subsequent, separate tax matter. Further, an LITC cannot refer a taxpayer to someone who charges a fee. 

For example, suppose an LITC refers a taxpayer in a controversy with the IRS to a member of the LITC’s 


pro bono panel. On behalf of the LITC, the pro bono representative resolves the dispute. The same taxpayer 

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owns a partnership interest in a family business under audit by the IRS and offers to pay the representative to 

represent the partnership, as the taxpayer understands the LITC can’t handle tax matters for entities. The pro bono 

attorney must decline the case and cannot refer the taxpayer to someone else who charges a fee to represent the 

partnership. Instead, the LITC or representative may refer the taxpayer to a state bar-maintained lawyer referral 

and information service that will provide the taxpayer with an unbiased referral to an attorney who has experience 

in the area of law appropriate to the taxpayer’s needs or an organization that provides pro bono assistance. 

xi. Recordkeeping and File Management 

Maintaining Records of Grant Expenditures 

LITCs must maintain adequate internal controls and retain financial accounting records to safeguard all funds, 

property, and other assets related to the grant. LITCs must have written procedures for approving expenditures 

from grant funds in accordance with the procurement, payment, and cost principles in the Uniform Guidance. At 

a minimum, the procedures should address: 

n	Which individuals have approval authority; 

n	When written approval is required; and 

n	What documentation must be submitted for an expense to be approved by the authorized official. 

The approval process may differ based on the size and type of expense. Also, LITCs must have written procedures 

to track their fixed assets and tangible personal property. To avoid subsequent disallowance or dispute based on 

unreasonableness or non-allocability of an expense, the grant recipient may seek the prior written approval from 

the LITC Program Office in advance of incurring special or unusual costs. Prior written approval should include 

the timeframe or scope of the proposed cost. The absence of prior written approval of any element of cost will 

not affect the reasonableness or allocability of that element, unless prior written approval is specifically referenced 

under 2 CFR § 200.407, such as purchases of $10,000 or more described in 2 CFR § 200.439(b)(2). Copies of 

any pre-approvals should be retained for three years from the date of purchase. Purchases of $10,000 or more 

should be noted in the clinic’s financial narrative in the year purchased. 

Maintaining Sufficient Detail in Client Records 

LITCs must maintain client case records to demonstrate client eligibility for program services and to document 

the services provided to taxpayers. In certain situations, attorneys’ fees (including fees for pro bono services) may 

be awarded in a judgment or settlement of an administrative or judicial proceeding concerning the determination, 

collection, or refund of tax, interest, or penalty. See IRC § 7430(a). Thus, a clinic should keep detailed 

contemporaneous case records of its controversy work so that if casework presents an opportunity to make a claim 

for attorneys’ fees, the clinic has adequate records to support an award. Awards of attorneys’ fees are program 

income and eligible as matching funds, if spent supporting LITC activities. 

For each increment of time for which fees are claimed, the records must: 

n	Identify the date on which the services were performed; 

n	Describe the nature of those services in detail; 
48 LOW INCOME TAXPAYER CLINICS

n	Identify the individual’s name and position of any representative for whom fees are claimed (e.g., supervisory 

attorney, student, or paralegal); and 

n	Include the associated incremental periods of time spent by that individual. 

The services provided by the LITC should be described in sufficient detail to enable the IRS to assess the 

reasonableness of the amount of time expended in relation to the service performed and to identify duplicated 

efforts, if any, by multiple clinic personnel. Case records should include classifications to describe the nature of the 

services provided. Suggested classifications include: 

n	Initial client interview; 

n	Research (identifying issues); 

n	Preparation of pleadings or other court documents; 

n	Preparation of letters (identifying the recipient and subject matter); 

n	Investigation of underlying facts (briefly describing the subject matter and information); 

n	Analysis of taxpayer or third-party records (identifying the records); 

n	Consultation with tax return preparer (identifying the preparer); 

n	Consultation or interview of third party (identifying the person); or 

n	Telephone conversations (identifying with whom the conversation was held and the subject matter). 

When a claim for attorneys’ fees is submitted, the IRS makes an initial determination as to whether client records 

are sufficiently detailed, based on the facts and circumstances of each case. For additional guidance on the recovery 

of attorneys’ fees, see Rev. Proc. 2016-17, 2016-11 I.R.B. 436. 

Using a Professional Case Management System 

Grant recipients are expected to use a case management system to assist with client eligibility screening and case 

assignment; help monitor the status of ongoing cases; input case notes; maintain accurate timekeeping records; 

track controversy outcomes; track case issues worked and where worked; and record educational, outreach, and 

advocacy activities for Interim and Year-End Reports. Information provided by LITCs is annually reported to 

Congress in Publication 5066, LITC Program Report, and may be included in the National Taxpayer Advocate’s 

Annual Report to Congress and other IRS publications and reports. The data can help identify trends or systemic 

issues. It is critical the information is complete and accurate. As case management software supports program 

activities, purchase of this type of software is an allowable cost under the LITC grant. 

BEST PRACTICE 

Consider using a cloud-based or remote-enabled case management system that will allow 

for remote access if needed. Explore enhancing the clinic’s case management system to the 

extent possible to capture information needed for progress reporting purposes (case issues 

worked, number of tax years involved, etc.) and timekeeping. 
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Backing Up Electronic Files Offsite 

LITCs should have an offsite backup file system in place for information stored electronically to enable 

resumption of business if a disaster or other work stoppage occurs. Using grant funds to develop a backup file 

system supports program activities and is an allowable cost under the LITC grant. For additional suggestions on 

risk management, see www.irs.gov/businesses/small-businesses-self-employed/preparing-for-a-disaster-taxpayersand-businesses and www.ready.gov/business. 

Keeping Client Records in a Secure Location 

Client records must be kept in a secure location (e.g., a locking file cabinet or password-protected electronic 

files). Before clinic employees, volunteers, or students leave the office each day, they must make sure that 

taxpayer information is stored in a locked area. If it is necessary to take taxpayer information out of the office, it 

must always be safeguarded. In addition, LITCs must have procedures in place to respond to a breach of client 

information and must notify the LITC Program Office by contacting their assigned Advocacy Analyst if a breach 

occurs. The notification should be both in writing and by telephone and take place as soon as is practicable, but 

not later than two business days from the time of discovery. See Section VI.D.i, Prevention and Response to Breach 

of Personally Identifiable Information. 

Retain Records That Document Compliance 

Federal award recipients must maintain financial records and supporting documents to substantiate compliance 

with grant requirements. Generally, such records must be maintained for three years from the date of submission 

of the Year-end Report. See 2 CFR § 200.334 for exceptions. 

Retaining Client Records 

Client records must be retained for a minimum of three years but may need to be retained longer to comply with 

all applicable IRS, federal, and state record retention requirements. State bars and other professional licensing 

organizations may impose additional recordkeeping requirements for case files. All clinicians should know the record 

retention standards applicable to them and the clinic and take all steps necessary to ensure those standards are met. 

Asking for Client Suggestions 

LITCs should seek comments from clients about the services received and ask for suggestions about how services 

might be improved. Many clinics routinely send surveys to clients at the conclusion of a case. It is important that 

when seeking suggestions, the information and data received is regularly compiled, reviewed, and considered as 

program policies, procedures, and services are assessed and changes are instituted. Comments that do not share 

any personally identifiable information may be helpful to include in grant applications and reports. 

xii. Representing Low-Income Taxpayers 

Qualified representatives, as defined in Section I.D, Key Terms and Definitions, must represent low-income 

taxpayers in controversies with the IRS. LITC grant funds must be used to support that representation. LITC 

grant funds may also be used to support representation in controversies with state or local tax authorities, if the 

LITC is representing the taxpayer in a related IRS controversy. 
50 LOW INCOME TAXPAYER CLINICS

Intake 

The intake process enables an LITC to determine whether it can represent a low-income taxpayer. During the 

intake process, LITC personnel collect information from the taxpayer to determine whether the taxpayer meets 

income and amount in controversy eligibility, and to gather information about the tax problem. The intake 

process should involve a robust interview with the taxpayer, which can be conducted in person or by phone. If by 

phone, a toll-free line should be available for taxpayers as well as translation services as necessary. 

LITCs should use an intake form, which can be paper or electronic, to capture the taxpayer’s information. Some 

clinics may ask taxpayers to complete the intake form independently before the interview, while others may 

meet with taxpayers to complete the form together. LITCs must record the taxpayer’s income information and 

that of the members of the taxpayer’s family unit, if applicable, on the intake form and solicit information so it 

promotes the development of trust between a qualified representative and applicant. If there is substantial reason 

to doubt the accuracy of the financial eligibility information provided by a potential client, the LITC must 

make appropriate inquiries to verify the information in a manner consistent with maintaining confidentiality of 

communications shared by the applicant. Any information disclosed during the intake process should be kept 

private and confidential. 

If a taxpayer does not meet the LITC’s eligibility requirements, the LITC may not refer the taxpayer to a 

representative who charges a fee; instead, the LITC should inform the taxpayer about a state or local bar 

association, society of accountants or enrolled agents, or other tax professional organization that provides pro bono 

assistance. If the professional organization thereafter refers the taxpayer to a representative who charges a fee, the 

LITC has still made an appropriate referral. 

BEST PRACTICE 

Include an intake question about how the taxpayer learned about the clinic. This information 

can help determine the effectiveness of the clinic’s outreach efforts. 

Assisting Taxpayers Through Consultations 

Many interactions a clinic will have with a taxpayer seeking assistance will be in the form of a consultation. A 

consultation is a discussion with a taxpayer designed to provide advice or counsel about a specific tax matter that 

does not result in representation of the taxpayer. An intake interview that does not result in the LITC representing 

the taxpayer may count as a consultation only if substantive advice or counsel is provided to the taxpayer 

about a specific tax matter. Merely referring the taxpayer to the IRS toll-free line or to a VITA site or tax return 

preparation service does not count as a consultation. For the Interim and Year-end Reports, consultations are 

counted and reported separately from controversy cases. For additional information on reporting consultations, 

see Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report, and for additional 

guidance on distinguishing consultations from cases for reporting purposes, see Form 13424-K, Low Income 

Taxpayer Clinic (LITC) Case Information Report. 
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Use an Engagement Letter When Opening a New Case 

When an LITC representative makes the determination to open a case after speaking with a new client and 

reviewing the information on the intake form, the representative is strongly encouraged to document it using an 

engagement letter or retainer agreement, signed by the representative and the taxpayer. An engagement letter or 

retainer agreement defines the specific matters for which the LITC will provide representation and protects both 

the representative and the taxpayer by informing both parties as to the agreement of assigned responsibilities 

during the professional relationship. Clearly defining the scope of the representation protects both the 

representative and the taxpayer from potential misunderstandings about what assistance the representative will and 

will not provide, particularly if the taxpayer has additional legal issues unrelated to the tax controversy. Written 

copies of the engagement letter or retainer agreement signed by both the representative and the taxpayer should be 

retained by the LITC and the taxpayer. 

LITCs must respect the attorney-client (or tax practitioner-client) relationship formed when an applicant comes 

in for a consultation. A representative must provide competent representation to a client, act with diligence and 

promptness regarding a client’s legal concerns, and keep a client informed of the proceedings in his or her case. A 

representative who fails to fulfill these duties may be subject to punitive actions from the organization responsible 

for issuing the representative’s license to practice. 

Low-Income Taxpayers and the 90/250 Requirement 

IRC § 7526(b)(1)(B)(i) requires that at least 90 percent of taxpayers represented by an LITC must have incomes 

that do not exceed 250 percent of the poverty level according to criteria established by the Director of OMB (as 

defined below). However, the Director of OMB has not established a poverty level or criteria. HHS publishes 

annual Federal Poverty Guidelines based on family unit size and geographic location, which are applicable to the 

LITC Program. See 89 Fed. Reg. 2961-2963 (Jan. 17, 2024). 

The 90/250 requirement applies only to taxpayers represented in controversy cases and does 

not apply to consultations or other LITC activities. 

A determination that a taxpayer is low-income does not entitle a taxpayer to representation by the LITC. Rather, 

financial eligibility is a threshold question each LITC must analyze when determining whether to accept a case for 

representation. Whether to represent an otherwise eligible taxpayer with a controversy is a matter for an LITC to 

determine with reference to the needs of the taxpayer, the facts at issue, and the resources available to the LITC. 

LITC Income Guidelines 

The LITC Program Office annually updates the income guidelines for the LITC Program in accordance with 

HHS’s annual publication of Federal Poverty Guidelines. Grant recipients must adopt new income guidelines 

within 30 days of the date of publication of the Federal Poverty Guidelines in the Federal Register (generally in 

late January). Based on the Federal Poverty Guidelines, the LITC income guidelines for controversy representation 

are shown in Figure 6. 
LOW INCOME TAXPAYER CLINICS

Figure 6, LITC Income Guidelines 

Income Ceiling 

(250 percent of Federal Poverty Guidelines) 

Size of Family Unit 48 Contiguous States, Puerto 

Rico, and D.C. Alaska Hawaii 

1 $37,650 $47,025 $43,275 

2 $51,100 $63,850 $58,750 

3 $64,550 $80,675 $74,225 

4 $78,000 $97,500 $89,700 

5 $91,450 $114,325 $105,175 

6 $104,900 $131,150 $120,650 

7 $118,350 $147,975 $136,125 

8 $131,800 $164,800 $151,600 

For each additional person, add $13,450 $16,825 $15,475 

Income for Purposes of the 90/250 Requirement 

“Income” is defined in accordance with the definition used by the U.S. Bureau of the Census. See 

https://www. census.gov/topics/income-poverty/about.html for a more detailed discussion of items classified 

as income. Income includes total annual cash receipts before taxes, subject to certain exceptions. For example, 

income includes: 

n	Gross salaries before payroll deductions; 

n	Net earnings from self-employment (gross receipts less business expenses); 

n	Alimony; 

n	Child support; 

n	Federally-funded and other public assistance; 

n	Social Security; 

n	Pensions and retirement income; 

n	Unemployment benefits; 

n	Workers’ compensation; 

n	Rents; 

n	Royalties; 

n	Scholarships; 

n	Dividends; 

n	Interest; 

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n	Net gambling winnings; and 

n	Survivor benefits or annuity payments. 

Income does not include: 

n	Proceeds received from the sale of property (e.g., stocks, bonds, a house, a car); 

n	Withdrawals from a bank account; 

n	Tax refunds; 

n	Gifts; 

n	Loans; 

n	Lump sum inheritances; 

n	Insurance payments; and 

n	Noncash benefits (e.g., employer-paid or union-paid portion(s) of employee fringe benefits). 

Determining Annual Income 

LITCs should generally determine program eligibility based on the taxpayer’s annual income at the time the 

taxpayer is seeking services. With seasonal workers or taxpayers whose financial situation has recently changed, the 

clinic may use a reasonable method to estimate the taxpayer’s income and then annualize that amount. 

Example 1: Determining a Taxpayer’s Annual Income 

A taxpayer seeking representation was unemployed for a year but began working again three months ago 

at a full-time job. The clinic should calculate the taxpayer’s income for the immediately preceding threemonth period and multiply by four to determine if the taxpayer meets the LITC income guidelines. 

Example 2: Determining a Taxpayer’s Annual Income 

A taxpayer seeking assistance works seasonally for eight months each year and cares for family members 

during the remainder of the year. The taxpayer earns no other income. The clinic should use the amount 

earned over the eight-month period as the taxpayer’s annual income to determine if the taxpayer meets the 

LITC income guidelines. 

Definition of Family Unit 

For purposes of the 90/250 requirement, a family unit is generally defined as an unrelated individual or a family. 

An unrelated individual is a person 15 years old or over not living with persons related by birth, marriage, or 

adoption. A family is a group of two or more persons related by birth, marriage, civil union, or adoption who 

live together. However, if related individuals live together, but the person seeking assistance from the LITC is 

financially independent, then that person may be treated as a family unit, distinct from relatives in the household. 

If two unrelated individuals live together, they constitute two family units. 

Subject to the general rules outlined above, LITCs have discretion on a case-by-case basis to include an unrelated 

individual as part of a family unit if that individual could be claimed as a dependent for federal tax purposes in 

the current year by the taxpayer or another member of the family unit. Clinics should exercise such discretion 

in a manner that is reasonable and consistent. Income of any person in a family unit must be included in the 

computation of the taxpayer’s income for purposes of applying the 90/250 requirement. 
54 LOW INCOME TAXPAYER CLINICS

Example: Determining the Size of a Family Unit 

A husband and wife come to the LITC seeking representation in a controversy with the IRS. The couple 

cares for two foster children who can be claimed as their dependents. The clinic may determine whether 

to treat the foster children as part of the family unit or as a separate family unit. However, if the foster 

children are treated as part of a single-family unit with the husband and wife, any state support payments 

received on behalf of the foster children must be included in the taxpayers’ income for purposes of 

applying the 90/250 requirement. If the foster children are treated as a separate family unit, the support 

payments would be excluded from the taxpayers’ income computation. 

Applying the 90/250 Requirement to the Number of New Cases Opened 

The 90/250 requirement applies only to taxpayers who the LITC has agreed to represent in controversy cases and 

does not apply to consultations or other LITC activities. LITCs apply the 90/250 requirement to the cases opened 

during the reporting period. Cases carried over from a prior grant year are not included in the calculation to 

determine compliance with the 90/250 requirement. 

If the LITC agrees to represent the taxpayer and takes steps to begin resolving the controversy, including 

developing a plan for advocacy, the case is included in the total number of cases for purposes of meeting the 

90/250 requirement. The case is counted in the total number of cases even if the taxpayer discontinues the 

relationship before advocacy occurs. Spouses represented with respect to a joint liability (i.e., arising from a 

Married Filing Jointly return) are treated as a single case for purposes of applying the 90/250 requirement. 

LITCs apply the 90/250 requirement by comparing the number of cases opened during the reporting period for a 

taxpayer whose income does not exceed 250 percent of the Federal Poverty Guidelines to the total number of cases 

opened during the reporting period. An LITC satisfies the 90/250 requirement if at least 90 percent of the cases 

opened during a reporting period are to provide representation to taxpayers whose incomes do not exceed 250 

percent of the Federal Poverty Guidelines. 

Example: Satisfying the 90/250 Requirement 

During the reporting period, the LITC opened 120 new representation cases and provided 92 

consultations to taxpayers that did not develop into a case (i.e., no representation agreement). The 90/250 

requirement applies only to the 120 representation cases and does not apply to the 92 interactions with 

taxpayers that were consultations. Thus, at least 108 of the 120 cases (90 percent) where representation 

was provided must have been for taxpayers whose incomes did do not exceed 250 percent of the 

applicable Federal Poverty Guidelines, based on the taxpayer’s geographic location and family size. 

Developing Acceptance Criteria for Cases Where a Taxpayer’s Income Is Above 250 

Percent of Poverty 

LITCs have discretion to choose when to represent a taxpayer whose income exceeds 250 percent of the Federal 

Poverty Guidelines, based on the taxpayer’s family unit size and location, provided that the number of such 

cases is no more than ten percent of the new cases opened during the reporting period. The grant recipient must 

disclose the number of such cases on its Interim and Year-end Reports on Form 13424-K, Low Income Taxpayer 

Clinic (LITC) Case Information Report. The criteria used to select cases where the taxpayer’s income is in excess 

of 250 percent of the Federal Poverty Guidelines should be reasonable and consistent and support the overall goals 

of the LITC Program – to provide representation, education, and advocacy to low-income and ESL taxpayers. 
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Changes in a Taxpayer’s Financial Status 

The determination of a taxpayer’s income for purpose of applying the 90/250 requirement is made at the time 

the clinic is determining whether to represent the taxpayer. A change in a taxpayer’s financial status during 

representation does not disqualify the taxpayer from continuing to receive clinic representation. The taxpayer’s 

failure to fully report his or her income at commencement of representation may be grounds for disqualification 

from representation or may require inclusion in the count of cases over 250 percent, depending upon the 

underlying circumstances. The LITC should examine the facts and document its decision and the factors leading 

to the decision of how to handle the situation. 

Amount in Controversy Limit 

The amount in controversy for any tax year generally should not exceed the amount specified in IRC § 7463 

($50,000). Thus, while most cases accepted by an LITC should involve amounts in controversy that do not exceed 

$50,000 in any tax year, LITCs may occasionally accept a case where the amount in controversy for a tax year 

exceeds the amount specified in IRC § 7463. 

The amount in controversy is the amount in dispute, whether the taxpayer is disputing that he or she owes the 

amount (e.g., challenging the validity of the underlying liability or seeking a refund), or whether the taxpayer 

acknowledges owing the amount and is merely trying to find a way to pay the amount in full or in part (e.g., 

seeking a collection alternative). The amount in controversy is the amount of the tax liability for which the 

taxpayer is seeking assistance. 

If the taxpayer is challenging the IRS’s actions (e.g., alleging that the IRS’s collection action was unauthorized (see 

IRC § 7433)) but is not disputing the amount owed, the amount in controversy is the amount which gave rise to 

the IRS’s actions which the taxpayer is challenging. 

Example 1: Calculation of the Amount in Controversy – Lien Withdrawal 

The IRS filed a Notice of Federal Tax Lien under IRC § 6323 when Taxpayer A failed to pay a liability 

for Tax Year 1. Taxpayer A engages an LITC to represent him in obtaining a lien withdrawal under 

IRC § 6323(j). The withdrawal will remove the notice of federal tax lien filing from the public record. 

When the LITC agrees to provide the representation, Taxpayer A owes $35,000 for Tax Year 1. Even 

though Taxpayer A is not challenging the amount due, the $35,000 balance is the amount in controversy 

because it is the amount associated with the IRS action for Tax Year 1 (lien filing) which Taxpayer A is 

challenging. 

The amount reflected in a statutory notice of deficiency (see IRC § 6212) or a notice of determination (see 

IRC §§ 6320 and 6330) does not always reflect the amount in controversy for LITC eligibility. For example, the 

taxpayer may receive a notice of deficiency for $60,000, consisting of tax liability attributable to three different 

tax issues. If the taxpayer does not dispute one of the issues, the amount in dispute may be less than the $60,000 

reflected in the notice of deficiency. 

Example 2: Calculation of the Amount in Controversy – Notice of Deficiency 

Taxpayer B receives a notice of deficiency for Tax Year 1 showing additional tax due of $49,000 and 

associated penalties of $3,000. Taxpayer B disputes the entire penalty amount and $42,000 of the $49,000 

tax due reflected in the notice of deficiency. The amount in controversy is $45,000 ($42,000 + $3,000). 
56 LOW INCOME TAXPAYER CLINICS

Interest on the Amount in Controversy 

Interest may be included in the calculation of the amount in controversy, depending on the nature of the 

controversy. For example, if the taxpayer disputes the validity of a tax liability and related penalties, the interest 

calculation is a percentage of the liability and will be established once the controversy is resolved administratively 

or in litigation. In that case, the LITC should exclude potential interest from the calculation of the amount 

in controversy. Where the taxpayer is seeking collection alternatives and not challenging the amount due, the 

amount in controversy will properly include tax, penalties, and interest. 

Example 3: Calculation of the Amount in Controversy – Interest 

Taxpayer C files a request for interest abatement under IRC § 6404 for $12,000 in interest that had 

accrued with respect to tax due in Tax Year 1. The tax liability has been resolved. Only the interest is in 

dispute and is, therefore, included in the amount in controversy. The amount in controversy is $12,000. 

Example 4: Calculation of the Amount in Controversy – Notice of Determination Under 

IRC § 6330 

Taxpayer D receives a notice of determination under IRC § 6330 concerning a proposed levy action. The 

notice of determination reflects a $40,000 liability for Tax Year 1, a $30,000 liability for Tax Year 2, and 

a $20,000 liability for Tax Year 3. Each of the liability amounts represents tax, penalties, and interest. 

Although Taxpayer D is disputing the entire $90,000 liability ($40,000 + $30,000 + $20,000), each tax 

year is reviewed separately to determine the relevant amount in controversy. For Tax Year 1, the amount 

in controversy is $40,000; for Tax Year 2, the amount in controversy is $30,000; and for Tax Year 3, the 

amount in controversy is $20,000. 

Example 5: Calculation of the Amount in Controversy – Balance Due 

Taxpayer E receives a bill (a notice and demand under IRC § 6303) from the IRS for $55,000 due for Tax 

Year 1. The amount due is comprised of $40,000 tax, $6,000 penalties, and $9,000 interest. Taxpayer D 

engages an LITC to represent him in submitting an offer in compromise (OIC) under IRC § 7122 for 

$4,000. The amount of the offer is not considered in determining the amount in controversy. Taxpayer D is 

trying to resolve the balance due, which includes interest. Therefore, the amount in controversy is $55,000. 

In the refund context, the taxpayer is seeking to collect an overpayment. The amount of interest to which the 

taxpayer may be entitled under IRC § 6611 will be established once the controversy is resolved administratively 

or in litigation, so interest is not included in the amount in controversy. The amount of interest is not being 

independently disputed, and the LITC should exclude potential interest from the calculation of the amount in 

controversy. In contrast, if the controversy involves a claim for refund of interest already paid, or the taxpayer 

disputes the amount of interest independently from the associated tax liability (e.g., a claim for interest abatement 

or interest suspension under IRC § 6404), then the LITC should include potential interest in the calculation of 

the amount in controversy. 

Example 6: Calculation of the Amount in Controversy – Refund Suit 

Taxpayer F filed a timely refund claim for Tax Year 1 for $12,000, plus any overpayment interest allowable 

under IRC § 6611. The IRS disallowed the refund claim. Taxpayer F engages an LITC to represent him 

in a refund suit in a U.S. district court. The interest is not independently disputed, as interest will be 

determined solely by the disposition of the taxpayer’s refund claim. Therefore, interest is not included in 

the amount in controversy of $12,000. 
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In a case involving collection or transferee liability where the payment of the balance due, including accrued 

interest is in dispute, the LITC should include interest paid in the calculation of the amount in controversy. If 

the dispute includes multiple quarters for a single tax year, the quarters for that single year should be totaled to 

calculate the amount in controversy for that year. 

Example 7: Calculation of the Amount in Controversy – Multiple Tax Periods 

The IRS determined that Taxpayer G is a responsible person within the meaning of IRC § 6672 and 

imposed a penalty for an unpaid employment tax liability arising from Taxpayer G’s business for each 

of the four quarters in Tax Year 1. The liabilities for the penalty are as follows: $15,000 (quarter one), 

$18,000 (quarter two), $10,000 (quarter three), and $12,000 (quarter four). The amount in controversy 

is $55,000 ($15,000 + 18,000 + 10,000 + 12,000) because the four quarters relate to a single tax year. 

Representing a Taxpayer With More Than $50,000 in Controversy 

A clinic may represent a taxpayer where the amount in controversy for a tax year exceeds $50,000. However, the 

grant recipient must disclose the number of such cases on its Interim and Year-end Reports on Form 13424-K, 

Low Income Taxpayer Clinic (LITC) Case Information Report and explain why each case was accepted for 

representation on Form 13424-N, Low Income Taxpayer Clinic (LITC) Program Narrative Report. A case only 

needs to be reported in the year it is opened. If a clinic intends to accept cases where the amount in controversy 

exceeds $50,000, the clinic must have a documented policy consistent with its organizational mission and is 

encouraged to take a facts and circumstances approach to decision-making. Factors an LITC may consider in its 

decision-making process may include: 

n	Whether the taxpayer has access to other representation if the LITC declines to take the case; 

n	Whether the LITC has particular language or cultural competencies that make it especially well-suited to 

represent the taxpayer; 

n	Whether the issue in the case is of significance to the low-income or ESL taxpayer populations; 

n	Whether the issue in the case is novel; 

n	Whether there is a high likelihood that the amount in controversy is highly overstated; and 

n	Whether the case would provide educational value for student representatives. 

If a clinic intends to accept cases above the $50,000 amount in controversy limit, it must 

formulate a policy and include the list of factors that will be considered in making the 

determination. The policy should also include who will make the determination, how it will be 

documented, and how exceptions will be tracked to ensure the information is available for 

reporting purposes. 
58 LOW INCOME TAXPAYER CLINICS

Participation in the U.S. Tax Court Clinical Program 

LITCs are strongly encouraged to participate in the U.S. Tax Court Clinical Program. Applying to participate in 

the program may be a condition of receiving an LITC grant award. Procedures for participation in the Clinical 

Program can be found at https://www.ustaxcourt.gov/clinics.html. Clinics will receive notification of acceptance 

into the program from the Clerk of the Court. There are two components to the program: 

n	The mailing “stuffer program”; and 

n	The calendar call program. 

A clinic may participate in one or both components. Each component has its own rules for participation. 

U.S. Tax Court Mailing Stuffer Program 

Clinics approved to participate in the Clinical Program will draft a brief “stuffer notice” containing the clinic’s 

contact information and advising petitioners of the availability of LITC services. The notice is submitted to the 

Tax Court and included in court mailings to local petitioners who indicate they do not have representation. 

Sample notices with suggested language and format are available from the Tax Court. 

If there is more than one LITC that participates in the stuffer program for the Tax Court in a particular place of 

trial, the clinics must submit a joint stuffer to the Tax Court. Participating in the stuffer program is outreach and 

can help increase the number of Tax Court petitioners reached by the clinic. Reaching petitioners earlier in the 

litigation process may help facilitate a much earlier resolution to their tax issues. 

U.S. Tax Court Calendar Calls 

Clinics participating in the Clinical Program may also attend U.S. Tax Court calendar call sessions. Generally, 

Tax Court calendar calls are held one to two times per year in each city where the Tax Court hears cases, although 

they can occur more frequently, depending on local need. When the Tax Court grants a taxpayer’s petition 

for a hearing, the Tax Court sends a notice of trial to each petitioner scheduled for that day and to the IRS 

Commissioner (respondent), approximately five months in advance of the calendar call. To efficiently handle 

cases, the Tax Court typically schedules many hearings on the first day of a calendar call session. On the first day 

of the scheduled week, each party is “called” before the judge to set hearings and trials and schedule the court’s 

“calendar” for the week. Thus, it is known as a “calendar call.” Some Tax Court hearings are resolved in a matter of 

minutes while others take longer. 

If a clinic identifies a taxpayer eligible for LITC representation, the clinic can choose whether to limit assistance 

to an informal consultation about the tax issues, offer brief service including negotiating informally with IRS 

counsel, or enter an appearance (limited or full scope) and represent the taxpayer before the Tax Court. See 

Section I.D, Key Terms and Definitions, Qualified Representative. 

U.S. Tax Court Pre-Trial Settlement Days 

The LITC Program Office, members of the IRS Office of Chief Counsel, Appeals, Collection, the American Bar 

Association Section of Taxation, LITCs, and the U.S. Tax Court continue to work together to create opportunities 

to bring together IRS Counsel, LITC attorneys and pro bono attorneys, and taxpayers in advance of calendar calls 

to negotiate settlement of pending cases. TAS employees also participate in Settlement Days to assist taxpayers 
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with tax issues attributable to non-docketed years. Local Taxpayer Advocates and their staff can work with and 

inform taxpayers about how TAS may assist with other unresolved tax matters, or to provide further assistance 

after the Tax Court matter is concluded. If a taxpayer experiences difficulties concerning a collection matter, TAS 

can also assist with collection alternatives. Clinics can learn about such opportunities and work to help set up 

Pre-Trial Settlement Days by contacting their local Chief Counsel office or an LITC Liaison committee member. 

A list of LITC representatives on this committee is available on the LITC Toolkit. 

Limited Entry of Appearance 

To improve efficiency and to encourage the assistance of unrepresented taxpayers, the U.S. Tax Court allows 

practitioners to enter a Limited Entry of Appearance. Limited representation means that the legal services 

provided are limited in scope and duration to less than full representation. Under Tax Court Rule 201(a), Tax 

Court Administrative Order No. 2020-03, and ABA Model Rule 1.2(c), an individual admitted to practice 

and in good standing with the Tax Court may file a limited appearance to a date or dates during a scheduled 

Trial Session. An LITC practitioner enters an appearance by signing the Tax Court petition (or other initial 

pleading) or by filing an Entry of Appearance or Substitution of Counsel. See U.S. Tax Court Rule 24. For more 

information about limited entry of appearance, see the Frequently Asked Questions at www.ustaxcourt.gov/ 

resources/practitioner/lea_faq.pdf. 

Representation by Students and Law Graduates 

Practice by students and law graduates before courts and local tax agencies is governed by the procedural rules of 

the court or agency with jurisdiction over the matter. Clinics should be familiar with and follow the rules of those 

jurisdictions. 

Eligibility for Special Appearance Authorization for Students and Law Graduates 

Practice before the IRS under a special appearance authorization issued by the Director of the LITC Program 

is limited to students and law graduates at an LITC or student tax clinic program working under the direct 

supervision of an individual authorized to practice before the IRS. See Delegation Order 25-18 (Rev. 5), 

IRM 1.2.2.15.18 (June 30, 2023). A student is an individual enrolled in an accredited law, business, or 

accounting program. A qualified law graduate is an individual who graduated from law school in 2022 or later 

and has not yet been admitted to the bar of any state, territory, or possession of the United States, including a 

Commonwealth or the District of Columbia. An individual who has applied to sit for the bar but has not been 

allowed to sit due to character, fitness, or moral qualifications does not meet the definition of a qualified law 

graduate. Similarly, an individual who has been denied admission to a bar due to character, fitness, or moral 

qualifications does not meet this definition of a qualified law graduate. 

LITCs may apply for a special appearance authorization using Form 13424-P, Application for Special Appearance 

Authorization and Form 13424-Q, LITC or STCP Student and Law Graduate Information letter and faxing them 

to the LITC Program Office at 877-477-3520. For more detailed instructions and copies of forms, please refer to 

the LITC Toolkit website. 
60 LOW INCOME TAXPAYER CLINICS

Submitting Form 2848 With Student/Law Graduate Representatives 

For a student or law graduate to represent a taxpayer before the IRS, the taxpayer must sign a Form 2848, 

Power of Attorney and Declaration of Representative, listing the student or law graduate and the supervisory 

representative. Any Form 2848 submitted to the IRS that lists a student or law graduate as a representative must 

include a special appearance authorization letter issued by the Director of the LITC Program or the IRS will not 

process the Form 2848. Clinics submitting authorizations that include a student or law graduate representative 

should check the LITC Toolkit for special submission instructions. LITCs may also submit these authorizations 

online indicating the form is for an LITC. 

Special Appearance Authorizations Automatically Expire 

The authority of the supervisory representative on the Form 2848 submitted to the IRS will remain effective until 

the form is withdrawn or revoked. However, the authority of any students or law graduates listed on Form 2848 

to represent the taxpayer automatically expires 130 days from the day the taxpayer signs the form. 

Clinics should avoid contacting the IRS to withdraw any student or law graduate as a taxpayer’s representative 

unless doing so is necessary to protect the interests of the taxpayer. A notice submitted to the IRS withdrawing a 

student or law graduate as a representative may result in the IRS inadvertently removing all representatives listed 

on the relevant Form 2848, including the supervisory representative. 

Substituting a Representative 

The supervisory representative has the authority to assign and reassign student or law graduate representatives to 

the taxpayer’s case without requiring the taxpayer to sign a new Form 2848 for each substitution, provided the 

taxpayer checks the box on line 5 of Form 2848 delegating authority to the representative to substitute or add 

representatives. Each time a student or law graduate representative is substituted for an existing representative, the 

clinic should submit to the IRS a copy of the original Form 2848 signed by the taxpayer (with box 5 checked), 

along with a new Form 2848 listing the substituted representative. The new Form 2848 listing the substituted 

representative does not require the taxpayer’s signature but should be signed and dated by the supervisory 

representative. If another student or law graduate is being added, remember that the student or law graduate on 

the Form 2848 initially will be limited to representing the taxpayer for only 130 days from when the taxpayer 

originally signed the Form 2848. If a student or law graduate is being substituted, the authority of the student or 

law graduate initially listed on the Form 2848 terminates. The authority of a student or law graduate added or 

substituted will expire 130 days from when he or she was added/substituted by the supervisory representative, not 

130 days from the date the Form 2848 was originally signed by the taxpayer. 

If an LITC encounters difficulty with the processing or recognition of Forms 2848 accompanied by a special 

appearance authorization, please contact Rudy Maldonado in the LITC Program Office at 559-550-8523 or the 

clinic’s assigned Advocacy Analyst. 

Conflicts of Interest and Student Representatives 

ABA Model Rule 1.7 provides that a lawyer should not represent a client if the representation involves a 

concurrent conflict of interest. Students and law graduates authorized to practice before the IRS are treated as 

lawyers to analyze ethics issues. Thus, students and law graduates who plan to seek employment with the IRS 
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while participating in an LITC should be wary of potential conflicts of interest. A student or law graduate has 

an obligation to inform clients that he or she is seeking employment with the IRS. Clients may give informed 

consent, confirmed in writing, to have the student or law graduate continue the representation. If a client does not 

consent to the student or law graduate continuing the representation, the student or law graduate must withdraw 

the employment application, or the Clinic Director must assign the case to an individual who does not have a 

conflict of interest. 

xiii. Education 

In addition to representing low-income taxpayers in disputes with the IRS, LITCs are required to educate 

low-income and ESL taxpayers about their taxpayer rights and responsibilities. Educational activities must be 

offered directly to low-income and ESL taxpayers, and clinics can expand their reach by educating staff of other 

organizations that assist the low-income or ESL taxpayer populations that the clinic is targeting for education 

purposes. Providing taxpayer education to low-income and ESL taxpayers serves multiple purposes, including: 

n	Informing taxpayers about the TBOR, including the right to retain representation; 

n	Helping taxpayers to understand their taxpayer rights and obligations and empowering them to exercise 

their rights; 

n	Informing taxpayers about their eligibility for tax credits such as the Earned Income Tax Credit (EITC); 

n	Publicizing the clinic and its services; and 

n	Generating controversy representation cases. 

Education topics should address tax issues of general significance to low-income and ESL taxpayers or of relevance 

in the local community, such as: 

n	Tax recordkeeping; 

n	Filing requirements and due dates; 

n	Eligibility for various deductions and credits; 

n	Worker classification; 

n	Identity theft; 

n	Innocent spouse relief; 

n	IRS audit and appeals process; and 

n	Collection alternatives. 

Educational activities may be offered in a variety of formats; however, LITCs are encouraged to offer face-to-face 

educational activities whenever possible. Using virtual formats for delivering educational activities is encouraged, 

especially where face-to-face is not possible. These virtual activities may be counted as educational activities for 

the purposes of Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report, if there is a 

reliable way to count the number of participants and the presenter and participants can interact so questions can 

be asked and answered. Clinics are encouraged to work with trusted community partner organizations to reach 

the taxpayer communities with which they are trying to connect. Examples of educational activities include but 

are not limited to: 
62 LOW INCOME TAXPAYER CLINICS

Making a presentation about federal taxpayer rights and responsibilities to an ESL class at a local community 

college; 

n	Presenting a workshop on collection alternatives, identity theft, or worker classification at a public library in 

a community where a significant portion of the residents are low-income or ESL; 

n	Holding a class for low-income workers about how to properly complete a Form W-4 for income tax 


withholding;
 

n	Leading a weekly discussion series at a community center where a significant portion of the residents are 

low-income or ESL on topics such as choosing a competent tax return preparer, determining filing status, 

and claiming credits such as the Child Tax Credit and the EITC; and 

n	Presenting a webinar with a live two-way webchat component about identity theft and recent tax scams for 

taxpayers in remote locations. 

Clinics may also offer education to staff and volunteers of community groups or organizations to help them make 

referrals and spot tax issues that their clients may be having. For example, a clinic may hold training for the staff of 

an immigrant rights organization about how taxpayers apply for and properly use an ITIN. Trainings may also be 

offered to professional organizations as a tool to recruit local qualified representatives to join the clinic’s pro bono 

panel. Trainings for tax professionals are “professional education activities.” Clinics may award CPE or CLE credits 

for educational activities about substantive tax issues impacting low-income or ESL taxpayers. All educational 

activities are reported on Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report. 

Educational Materials 

LITCs are responsible for creating, printing, and distributing the materials used to educate taxpayers. Materials 

should be accessible to ESL taxpayers and prepared in languages spoken in the community for which the 

LITC provides services. Some educational resources are shared on the LITC Toolkit. The TAS website 

(www.taxpayeradvocate.irs.gov) also has sample materials on a variety of tax-related topics. The QTE is responsible 

for reviewing all educational materials for accuracy before distribution, whether they are prepared by the clinic or 

adapted from another organization or clinic’s materials. 

BEST PRACTICE 

When asked, many clinics will share their educational materials and will allow other clinics 

to adapt the materials for their use. Collaboration among LITCs helps all clinics to use their 

resources most effectively by enabling them to concentrate on creating new materials on 

select topics or new areas. 
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xiv. Advocacy 

The third prong of the LITC mission is to identify and advocate for issues that impact low-income and ESL 


taxpayers. LITCs may achieve this goal through a variety of methods, including but not limited to:
 

n	Participating in advocacy projects with professional organizations; 

n	Responding to public requests for comments to IRS regulations, procedures, or guidance; 

n	Preparing and filing an amicus brief to alert a court about the concerns of low-income or ESL taxpayers; 

n	Authoring articles in scholarly journals or general interest publications on topics impacting low-income or 

ESL taxpayers; 

n	Appearing on television or radio to raise awareness about tax issues that affect low-income or ESL taxpayers; 

n	Producing public service announcements; and 

n	Submitting issues to the Systemic Advocacy Management System (SAMS), available through the IRS 

website at www.irs.gov/Advocate/Systemic-Advocacy-Management-System-SAMS. 

To report these activities, use Form 13424-C, Low Income Taxpayer Clinic (LITC) Advocacy Information Report, 

or Form 13424-N, Low Income Taxpayer Clinic (LITC) Program Narrative Report. Grant recipients must ensure 

that advocacy efforts do not rise to the level of certain lobbying actions that are prohibited as a use of federal grant 

funds. See Section VI.D.iii, Lobbying Restrictions. 

xv. Preparing Tax Returns and Individual Taxpayer Identification Number 

Applications 

Generally, if low-income taxpayers require assistance with tax return preparation or an application for an ITIN, 

they should be referred to the VITA program, a Tax Counseling for the Elderly (TCE) site, or another free tax 

return preparation service. Some IRS TACs will accept ITIN applications and verify taxpayer documents, but they 

will not prepare tax returns. For a list of TACs that provide in-person document review, see www.irs.gov/help/taclocations-where-in-person-document-verification-is-provided. Note that TAC offices are open on an appointmentonly basis; appointments can be scheduled by calling 844-545-5640. LITC grant funds cannot be used to fund 

return preparation and related activities, such as those performed by VITA or TCE programs. 

An LITC can help with a federal tax return, a claim for refund, or an ITIN application if such assistance is 

necessary to resolve a dispute with the IRS or is ancillary to the LITC’s ESL education activity. The clinic may not 

charge a fee (even if it is a nominal fee) for preparing a tax return or a claim for refund. An LITC or an individual 

associated with an LITC that does not charge a fee is specifically excluded from the definition of a “Tax Return 

Preparer” as set forth in Treas. Reg. § 301.7701-15(f), for purposes of preparer penalties, and is not required to 

obtain a preparer tax identification number. 

Clinics are prohibited from including tax return, claim for refund, or ITIN application preparation among a list 

of services provided in any advertising materials. See Section VI.C.iv, Developing a Community Outreach Plan, for 

more information. 
64 LOW INCOME TAXPAYER CLINICS

Example 1: Permissible Tax Return Preparation – Controversy Resolution 

LITC Q is representing Taxpayer E regarding an OIC under IRC § 7122. Taxpayer E must file all tax 

returns she is legally required to file before the IRS will process an OIC request. Taxpayer E has not filed 

returns for the last three tax years. Because filing the delinquent tax returns is necessary to have the OIC 

considered and to resolve the controversy, LITC Q may assist Taxpayer E in completing her tax returns for 

the last three tax years. 

Example 2: Impermissible Tax Return Preparation – No Tax Controversy 

Assume the same facts as in Example 1, except the OIC is accepted by the IRS. As a condition of the IRS’s 

acceptance of the offer, Taxpayer E must timely file returns for the five-year period beginning with the 

date of acceptance of the offer. LITC Q cannot assist Taxpayer E in completing and filing her returns due 

after the offer is accepted because the timely filing of future tax returns is not a tax controversy. 

Example 3: Permissible Tax Return Preparation – Controversy Resolution 

Assume the same facts as Example 2, except Taxpayer E fails to file a return required to be filed during the 

five-year period beginning with the date of acceptance of the OIC and the IRS defaults the offer. Taxpayer 

E engages LITC Q to represent her in trying to get the offer reinstated. LITC Q may assist Taxpayer E 

in completing the delinquent return because reinstatement into the OIC program is a controversy matter 

and filing the return is necessary to resolve the controversy. 

Example 4: Permissible Tax Return Preparation – Ancillary to ESL Education 

LITC R is conducting a program to inform taxpayers about required recordkeeping for tax return filing 

purposes. LITC R did not advertise return preparation as a service available to taxpayers who attend 

the educational event. Nonetheless, at the end of the event, one of the attendees, Taxpayer F, asks an 

employee of LITC R to “look” at her self-prepared tax return before she files it to determine if it is correct. 

The employee of LITC R looks at the return and identifies several errors. The employee of LITC R may 

assist Taxpayer F in correcting the return because the assistance offered to Taxpayer F is ancillary to ESL 

education and outreach. 

Example 5: Impermissible Tax Return Preparation – Not Ancillary to ESL Education 

LITC S holds a monthly workshop about EITC. At the end of each workshop, LITC S’s personnel offer 

to prepare a tax return for attendees eligible to claim the EITC. LITC S may not prepare tax returns 

under these circumstances because attendees have not indicated there is a controversy for which the 

returns are required to resolve, and the routine offering of such service does not qualify as ancillary. It is 

improper to make this offer at the end of each workshop. 

D. NATIONAL POLICY REQUIREMENTS AND ADMINISTRATIVE 

REQUIREMENTS 

i. General Compliance 

By accepting funds under this grant, the grant recipient agrees to comply with all terms and conditions for the 

grant, which are governed by: 

n	26 U.S.C. § 7526; 
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n	The terms and conditions contained in this publication; 

n	Standard representations (assurances) and certifications; 

n	Any requirements, prohibitions, or restrictions imposed by the legislation appropriating federal funds for 

this award; 

n	Other guidance issued by OMB after the Full Grant Application or NCC Request has been received by the 

LITC Program Office; and 

n	Any additional specific conditions in the NOA. 

Grant recipients are responsible for monitoring clinic operations to ensure that all activities conducted under 

the award comply with applicable federal requirements and that performance expectations are being achieved. 

Grant recipients are also responsible for performing in accordance with the standards of operation, meeting all 

compliance requirements, making proper expenditures, accounting for and properly documenting the use of 

federal and matching funds and the source of contributions, and completing timely and accurate reporting of 

grant activities and finances. 

Uniform Guidance Sets Forth Key Responsibilities for Federal Grant Recipients and 

Federal Grantors 

Administrative requirements governing federal awards are set forth in the Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as the Uniform Guidance. 

The Uniform Guidance helps ensure the highest integrity in the financial management and operation of federal 

grant programs and strengthens accountability for federal funds by improving policies that protect against waste, 

fraud, and abuse. In addition, the guidance aims to minimize the time applicants and grant recipients must spend 

complying with administrative requirements. The Uniform Guidance was recently updated to further reduce the 

administrative burden on both agencies and grant recipients and to clarify and simplify the guidance to make it 

more accessible and readily comprehensible. See 89 Fed. Reg. 30046-30208 (Apr. 22, 2024). 

The CFR contains all the general and permanent rules published in the Federal Register by the executive 

departments and agencies of the Federal Government. The Uniform Guidance is found at 2 CFR Part 200, and 

the Treasury Department’s implementation of the Uniform Guidance is found at 2 CFR Part 1000. The electronic 

CFR is updated daily and is located at www.ecfr.gov. All applicable provisions from 2 CFR Parts 200 and 1000 are 

incorporated into the program requirements outlined in this publication and into all LITC grant awards. 

Standard Representations (Assurances) and Certifications 

Applicants that create a new registration and existing clinics completing their annual registration renewals are 

required to review financial assistance representations and certifications before their registration on SAM.gov can 

be activated. This section lists some of the standard representations and certifications and some of the specific 

provisions as implemented by the Department of the Treasury or the IRS. 
66 LOW INCOME TAXPAYER CLINICS

z	 Exempted from the requirement to provide or pay for such return transportation by the federal 

department or agency providing or entering into the grant, contract, or cooperative agreement; or 

z	 The employee is a victim of human trafficking seeking victim services or legal redress in the 

country of employment or a witness in a human trafficking enforcement action. 

Digital Accountability and Transparency Act of 2014 

The Digital Accountability and Transparency Act of 2014 (the Data Act) requires the U.S. Department of 

the Treasury to establish common standards for financial data provided by all government agencies on the 

USASpending website to increase transparency in federal expenditures and to make the information more 

accessible to the public. Among other objectives, the Data Act aims to simplify reporting for entities receiving 

federal funds and improve the quality of submitted data. LITC goals are also reported to the USASpending 

database that allows the public to research the use of public funding. 

Non-Procurement, Debarment and Suspension 

See Section III.C.iv, Debarment and Suspension, for further information. 

Drug-Free Workplace 

LITCs must satisfy requirements for a drug-free workplace pursuant to 41 U.S.C. §§ 8101-06, 2 CFR Part 182, 

and 31 CFR Part 20, Subpart B and C. 

Trafficking Victims Protection Act of 2000 

The Trafficking Victims Protection Act (TVPA) of 2000, as amended (22 U.S.C. § 7104), requires any agency 

that awards grants to include a condition authorizing the agency to terminate the grant if the grant recipient 

engages in certain activities related to trafficking in persons. As part of implementing the Act, the Office of 

Federal Financial Management has established terms that must be included in every grant agreement. See 

2 CFR § 175.105. 

The IRS may terminate the award, without penalty, if the grant recipient engages in, or uses labor recruiters, 

brokers, or other agents in violation of the TVPA of 2000. The applicable terms are: 

You, as the grant recipient, and your employees may not: 

a. Engage in severe forms of trafficking in persons during the period that the award is in effect; 

b. Procure a commercial sex act during the period that the award is in effect; 

c. Use forced labor in the performance of the award; or 

d. Engage in acts that directly support or advance trafficking in persons, including the following acts: 

i.	 Destroying, concealing, removing, confiscating, or otherwise denying an employee access to that 

employee’s identity or immigration documents. 

ii.	 Failing to provide return transportation or pay for return transportation costs to an employee from 

a country outside the United States to the country from which the employee was recruited upon the 

end of employment if requested by the employee, unless: 
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iii.	 Soliciting a person for employment, or offering employment, by means of materially false or 

fraudulent pretenses, representations, or promises regarding that employment. 

iv.	 Charging recruited employees’ placement or recruitment fees. 

The IRS may unilaterally terminate the award, without penalty, if it determines that the grant recipient has 

violated one of the provisions in a, b, c, or d above, or if the IRS official authorized to terminate the award 

determines that an employee of the grant recipient violated a prohibition in items a, b, c, or d above through 

conduct that is either: 

n	Associated with performance under the award; or 

n	Imputed to the grant recipient using the standards and due process for imputing the conduct of 

an individual to an organization provided in 2 CFR Part 180, OMB Guidelines to Agencies on 

Governmentwide Debarment and Suspension (Non-Procurement), as implemented by the Department of 

the Treasury at 31 CFR Part 19. 

Federal Funding Accountability and Transparency Act 

The Federal Funding Accountability and Transparency Act (FFATA) of 2006, as amended, is intended to 

empower Americans with the ability to hold the government accountable for spending decisions. Each applicant 

must ensure it has the processes and systems in place to comply with the FFATA reporting requirements. Unless 

exempted from this requirement under paragraph d of Appendix A to 2 CFR Part 170, any grant recipient with 

total funding anticipated to equal or exceed $300,000 in federal funding must report to http://www.fsrs.gov the 

total compensation for each of the grant recipient’s five most highly compensated executives for the preceding 

completed fiscal year. See Appendix A to 2 CFR Part 170. 

Prevention and Response to a Breach of Personally Identifiable Information 

OMB requires that when a grant recipient creates, collects, uses, processes, stores, maintains, disseminates, 

discloses, or disposes of personally identifiable information within the scope of a federal award, the IRS shall 

ensure that the grant recipient has procedures in place to respond to a breach. In addition, a grant recipient must 

timely notify the IRS if a breach occurs; see Section VI,C,xi, Recordkeeping and File Management, Keeping Client 

Records in a Secure Location. Because LITCs have access to the personally identifiable information of their clients 

and their prospective clients, LITCs must have procedures in place to respond to a breach and must notify the 

LITC Program Office if a breach occurs. See OMB Memorandum M-17-12, Preparing for and Responding to a 

Breach of Personally Identifiable Information (Jan. 3, 2017). 

Certain Criminal Law Violations 

Federal law prohibits the award of grant funds to any corporation convicted of a felony criminal violation under any 

federal law within the preceding 24 months, where the IRS is aware of the conviction, unless a federal agency has 

considered suspension or debarment of the corporation and determined that denial of the grant is unnecessary to 

protect the interests of the government. See Pub. L. No. 117-328, Div. E, Title VII, § 745 (Dec. 29, 2022). 
68 LOW INCOME TAXPAYER CLINICS

In addition, all applicants must disclose all violations of federal criminal law involving fraud, bribery, or gratuity 

violations potentially affecting the grant award. Failure to make required disclosures can result in any of the 

remedies described in 2 CFR § 200.339, including suspension or debarment. See 2 CFR § 200.113. 

Buy American Act 

Grant recipients must comply with the Buy American Act, 41 U.S.C. §§ 8301-8305, which requires that all 

unmanufactured articles, materials, and supplies purchased using grant funds be mined or produced in the United 

States and that all manufactured articles, materials, and supplies purchased using grant funds be manufactured 

in the United States substantially all from articles, materials, or supplies mined, produced, or manufactured in 

the United States. A conviction for violating the Buy American Act causes debarment from federal grants and 

contracts. The requirement to Buy American does not apply to information technology that is a commercial item, 

products for which the expected value of the procurement is $10,000 or less, products for use outside the United 

States, foreign products when domestic products are unavailable or are of unacceptable quality, or foreign products 

excepted by certain trade agreements. The IRS may waive the requirement to Buy American if its application 

would be inconsistent with the public interest or the cost would be unreasonable. 

Other Applicable Laws and Regulations 

Programs involving use of federal funds are governed by a wide variety of federal laws and regulations. These include: 

n	Restrictions on political activities (18 U.S.C. §§ 595, 598, 600-603); 

n	The national preservation program requirements (54 U.S.C. § 300101); 

n	Whistleblower protections (41 U.S.C. § 4712); 

n	Rules governing allowable costs (41 U.S.C. §§ 4304 and 4310); 

n	Environmental requirements of the Clean Air Act (42 U.S.C. § 7401); and 

n	The non-pollution requirement of the Federal Water Pollution Control Provisions (33 U.S.C. § 1251). 

Conflict of Interest Policy 

Pursuant to 2 CFR § 200.112, applicants and grant recipients must have a written conflict of interest policy that 

contains the terms as listed in this section. LITCs must promptly disclose in writing to the LITC Program Office 

any potential conflict of interest situation and how the conflict was resolved. 

At a minimum, an LITC grant recipient’s conflict of interest policy (“Policy”) must: 

n	Apply to at least the grant recipient’s employees, officers, members of its board of directors (including nondirector members of committees), and pro bono panel members (“Covered Individuals”); 

n	Apply to at least all grant recipient matters involving the use of LITC grant funds and matching funds, in 

whole or in part, including, but not limited to, grants, contracts, procurements, leases, investments, other 

commitments of grant recipient resources, and personnel matters; 

n	Cover at least situations when an outside interest, activity, or relationship influences or appears to influence 

the ability of a Covered Individual to exercise objectivity, or impairs or appears to impair his or her ability to 

perform his or her responsibilities impartially and in the best interests of the grant recipient (“Conflict”); and 
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n	Cover at least situations when an outside interest, activity, or relationship influences or appears to influence 

the Covered Individual’s impartiality or duty of loyalty to a client. 

The Policy must require Covered Individuals to avoid legal, financial, personal, or other Conflicts and potential 

Conflicts involving the grant recipient and to promptly disclose any such Conflicts and potential Conflicts that 

arise. Covered Individuals must recuse themselves from a position of decision-making authority or influence on 

decisions or actions regarding any such Conflicts and potential Conflicts until resolved. 

Covered Individuals must report on any situations they know or reasonably should know will present a Conflict 

or a potential Conflict. The Policy must specify to whom Conflicts must be reported and how Conflicts will be 

addressed and resolved. Covered Individuals may not participate in any situation involving a Conflict or potential 

Conflict, unless the grant recipient determines, through these procedures, that the: 

n	Conflict or potential Conflict is not substantial; and 

n	Covered Individual’s participation is in the best interest of the LITC and the LITC’s clients. 

Civil Rights Protection and Other Federally Mandated Compliance 

This section describes the data collection and reporting obligations required of LITC grant applicants by the IRS 

to meet their responsibilities under these laws. This information is required pursuant to the civil rights statutes 

and the regulations of the Department of Justice and the Department of the Treasury. See Executive Order 12250, 

Leadership and Coordination of Nondiscrimination Laws, which has been implemented at 28 CFR Part 41. 

(Applicants will provide this information when completing the Form 13424-M, Low Income Taxpayer Clinic 

(LITC) Application Narrative, and the Project Abstract.) 

All applicants for federal funding must provide information to demonstrate compliance with the following: 

n	Title VI of the Civil Rights Act of 1964 (Public Law 88-352), as amended, which prohibits discrimination 

on the basis of race, color, or national origin; 

n	Section 504 of the Rehabilitation Act of 1973 (Public Law 93-112), as amended, which prohibits 


discrimination on the basis of disability;
 

n	Title IX of the Education Amendments of 1972 (Public Law 92-318), as amended, which prohibits 


discrimination on the basis of sex in education programs or activities;
 

n	Age Discrimination Act of 1975 (Public Law 94-135), as amended, which prohibits discrimination on the 

basis of age; 

n	31 CFR Parts 22, 23, and 28, are the Department of the Treasury’s regulations implementing applicable 

provisions of Title VI of the Civil Rights Act of 1964, the Age Discrimination Act of 1975, and Title IX 

of the Education Amendments of 1972, respectively. 

n	Note that each Part sets forth a requirement that recipients keep records in a form and containing 

information that Treasury determines may be necessary to ascertain whether the recipient is complying 

with the relevant provisions of each Act. The requirements are found at 31 CFR §§ 22.6(b), 23.34(a), 

and 28.605(b). 
70 LOW INCOME TAXPAYER CLINICS

n	Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, requires 

that federal agencies work with recipients of federal financial assistance to ensure that their programs and 

activities normally provided in English are accessible to those with limited English proficiency, including 

through oral and written translation when necessary; 

n	Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin 

Discrimination Affecting Limited English Proficient (LEP) Persons, which provides in part that recipients 

are required to take reasonable steps to ensure meaningful access to their programs and activities by LEP 

persons. See 70 Fed. Reg. 6067-76 (February 4, 2005); 

n	Executive Order 13988, Preventing and Combating Discrimination on the Basis of Gender Identity 

or Sexual Orientation, requires agencies to examine their programs and policies to prevent and combat 

discrimination on the basis of gender identity or sexual orientation; and 

n	Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the 

Federal Government, requires that all federal agencies select a program of the agency for a review to assess 

whether there are barriers to participation for members of underserved communities in government services 

and contracts and to take actions to remove identified barriers. The order revoked previous Executive Order 

13950 of September 22, 2020 (Combating Race and Sex Stereotyping). 

All LITCs are required to display Publication 4053, Your Civil Rights Are Protected. 

The Department of the Treasury is planning to issue guidance about LITC grant recipients’ requirements to 

collect data pursuant to the civil rights laws. Once the guidance is issued, the LITC Program Office will provide 

the guidance via the LITC Toolkit. For additional information, review the Department of the Treasury’s Civil 

Rights Toolkit for grant recipients at the following link, https://home.treasury.gov/system/files/306/CR_TK_ 

OCRE_508.pdf. 

Protection Against Reprisal 

No recipient or associate of the recipient may intimidate, threaten, coerce, or discriminate against any individual 

to interfere with any right or privilege protected by the laws identified in this section. No recipient or associate 

of the recipient may intimidate, threaten, coerce, or discriminate against any individual because the individual 

has made a complaint, testified, assisted, or participated in an investigation, proceeding, or hearing involving 

enforcement of the laws identified in this section. 

Consequences for Failing to Comply With National Policy and Program Requirements 

A detailed list of the actions the LITC Program Office may take for failure to comply with National Policy 

and program requirements specific to the LITC is addressed in Section VIII, Award Modification, Suspension, 

Termination, or Withdrawal. 
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ii. Managing Grant Funds 

Accessing LITC Grant Funds in the Payment Management System 

Grant funds are paid through the Payment Management System (PMS), maintained by HHS’s Payment Support 

Center (PSC). PMS allows a grant recipient to make an online request for payment of federal funds. After a request 

is processed and approved, funds are directly deposited into the grant recipient’s bank account through a process 

called Electronic Funds Transfer (EFT). Funds are generally available within one business day of the request. 

Accessing the Payment Management System 

LITC Program Office staff can assist new grant recipients with establishing accounts in PMS. Grant recipients 

must obtain a username and password to use the system and complete a form to set up direct deposit of funds into 

the grant recipient’s bank account. Information regarding the EFT procedure is available on the PMS PSC website 

at https://pms.psc.gov. For details about seeking historical payment information for audits and other purposes, see 

Section IV.E.iii, Meeting the Matching Funds Requirement, OMB Audit Requirement. 

The PSC has online FAQs and training. Grant recipients are encouraged to visit the website to view these 

resources. Those experiencing problems accessing funds should contact the help desk at 877-614-5533 or email to 

PMSSupport@psc.hhs.gov. 

Obtaining Reimbursement for Eligible Expenses 

Grant recipients may request reimbursement of funds for allowable expenses they already paid or that will be paid 

within three business days of receipt of the funds from PMS and must make requests in accordance with their 

actual immediate cash needs in carrying out LITC operations. The timing and amount of EFT payments must 

be as close as is administratively feasible to the actual disbursements by the grant recipient for direct program 

or project costs and the proportionate share of any allowable indirect costs. If an expense has been paid, grant 

recipients are encouraged to draw down those funds as soon as possible. PMS accounts are placed in restricted 

status 90 days after the end of the reporting period. If grant recipients attempt to draw down funds after the 

90-day period, LITC Program Office management approval is required for release of the funds from PMS. This 

added approval step may delay release of grant funds. Questions regarding disbursement of funds should be 

directed to the grant recipient’s assigned Advocacy Analyst. 

BEST PRACTICE 

Grant recipients should regularly draw down grant funds. If funds are drawn down less than 

biannually, this is often a sign that the organization is not regularly reviewing its budget vs. 

actual expenditures, which is a potential financial weakness. An LITC experiencing difficulties 

within the PMS system that it cannot resolve with PMS should contact its assigned Advocacy 

Analyst for assistance. 
72 LOW INCOME TAXPAYER CLINICS

Grant Funds Must Be Held in an Insured Account 

Grant recipients must maintain advances of federal grant funds in interest-bearing accounts at a bank with Federal 

Deposit Insurance Corporation (FDIC) insurance coverage. The balance exceeding the FDIC coverage must be 

collaterally secured unless: 

n	The grant recipient receives less than $250,000 in federal awards per year; 

n	The best reasonably available interest-bearing account would not be expected to earn interest in excess of 

$500 per year on federal cash balances; 

n	The depository would require an average or minimum balance so high that an interest-bearing account 

would not be feasible, given the grant recipient’s expected federal and nonfederal cash resources; or 

n	A foreign government or banking system prohibits or precludes interest-bearing accounts. 

Interest Earned on Grant Funds 

Grant recipients must annually remit to the federal government any interest in excess of $500 per year earned on 

advances of federal grant funds and may keep up to $500 of interest earned per year for administrative expenses. 

Interest earned on federal advance payments deposited in interest-bearing accounts must be remitted annually to 

HHS via PMS. See 2 CFR § 200.305(b)(12). 

iii. Lobbying Restrictions 

No federal grant funds or matching grant funds may be used, either directly or indirectly, to support the 

enactment, modification, or adoption of any law, regulation, or policy at any level of government. Some 

exceptions to this general rule may exist pursuant to an express authorization by Congress. There are two types of 

lobbying activities – direct lobbying and grassroots lobbying. 

Direct lobbying includes contacting a member of Congress, a state or local legislator, or any of their staff 


members to influence the legislator to take a position or action on a specific piece of legislation or potential 


legislation.
 

Grassroots lobbying includes activities that encourage third parties, members of special interest groups, or the 

public to contact federal, state, or local government officials in support of, or in opposition to, a legislative policy 

or appropriations matter. This applies to activities both before and after introduction of the legislation. 

Any entity receiving grant funds from another federal source, either directly or indirectly, may 

be subject to additional restrictions on lobbying. 

Grant recipients are prohibited from using federal grant funds and matching funds to: 

n	Visit or send letters to members of Congress, state or local legislators, or any of their staff members urging 

them to favor or oppose specific legislation pending under their jurisdiction; 
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n	Develop materials designed to advocate for the enactment or repeal of any legislation or provide such 

materials to anyone; 

n	Draft or assist in the drafting of legislation or provide comments on draft legislation; 

n	Pay, directly or indirectly, for any efforts intended to or designed to influence a member of Congress or a 

state legislators to favor or oppose any legislation or appropriation, whether before or after introduction; or 

n	Engage in any legislative liaison activities, including attendance at legislative sessions or committee hearings, 

gathering information regarding legislation, or analyzing the effect of legislation, when such activities are 

carried out in support of or in knowing preparation for an effort to engage in unallowable lobbying. 

LITC employees are prohibited from engaging in any lobbying activities during the portion of 

time that their salaries are paid from federal grant funds or matching funds. 

Grant recipients may use federal grant funds and matching funds to: 

n	Educate the public or constituents on legislative issues, so long as the education is not part of a broader 

effort to directly or indirectly (grassroots lobbying) influence legislators on a specific piece of legislation or 

legislative issue; 

n	Respond to documented requests from members of Congress, state legislators, or other officials (see 


2 CFR § 200.450(c)(2)(i));
 

n	Interact with agency liaisons, such as the National Taxpayer Advocate or Local Taxpayer Advocates, 


regarding program-related issues;
 

n	Respond to a personal or public invitation from the IRS for comments on proposed tax regulations or 

guidance that impacts low-income and ESL taxpayers; 

n	Partner with professional organizations to identify and propose solutions for issues impacting low-income 

and ESL taxpayers (however, such efforts may not attempt to influence the introduction, enactment, or 

modification of any federal or state legislation); 

n	Contact government officials regarding broad social, economic, or other issues, so long as the contact is 

not part of an effort to influence Congress or the state legislature on an actual or potential specific piece of 

legislation; or 

n	Discuss broad social, economic, or other issues on listservs or blogs, so long as the contact is not part of an 

effort to influence Congress. 

The LITC Program Office recognizes that the above list of prohibited and permitted activities will not answer 

every situation that arises. If a grant recipient has any question as to whether an anticipated activity could fall 

within the scope of these rules, it should contact the assigned Advocacy Analyst prior to engaging in such activity. 
LOW INCOME TAXPAYER CLINICS

Disclosure Requirements 

Grant recipients may expend non-LITC funds (i.e., funds that are neither federal grant funds nor matching 

funds) on lobbying activities. However, under the Byrd Amendment (31 U.S.C. § 1352), grant recipients may 

be required to disclose lobbying activities conducted if the activities relate to lobbying regarding the making or 

awarding of a grant and the organization receives more than $100,000 in federal grant funds. 

Figure 7, Sources of Guidance on Lobbying Activities 

Source of 

Restriction 2 CFR Part 200 Byrd Amendment 31 U.S.C. § 1352 

Publicity and 

Propaganda/ 

Appropriations 

Laws Restrictions 

Type of Funds 

Affected by 

Restriction 

Federal grant 

funds and 

matching funds 

Restriction applies to federal grant 

funds and matching funds. Although 

the restriction does not apply to 

funds that are neither federal grant 

funds nor matching funds, contacts 

with members of Congress may 

need to be disclosed. 

Federal grant funds 

and matching funds 

Lobbying topics 

covered by 

Restriction 

All subject matters 

Limited to lobbying regarding the 

making or awarding of a grant; it 

does not appear to apply to lobbying 

on general program legislation (i.e., 

to expand the subject matter of the 

program, as opposed to the amount 

of money awarded for program 

purposes which may increase the 

award to the grant recipient). 

All subject matters 

Stage of legislation 

covered by 

restriction 

All stages, 

including before 

introduction 

All stages, including before 

introduction 

Legislation pending 

before Congress 

Applicability to 

Grassroots Lobbying 

Yes, it is 

prohibited. 

No, it is not prohibited, so long as 

no federal funds are used for the 

grassroots lobbying effort. 

Yes, it is prohibited. 

Applicability to 

advocating at the 

state level 

Yes, prohibition 

applies to state 

level activities. 

No, the prohibition does not apply to 

state level activities. 

No, the prohibition 

does not apply to state 

level activities. 

Exceptions for 

when information 

is specifically 

requested by 

member of Congress 

Yes, there is an 

exception which 

permits a response 

to a documented 

request. 

Yes, there is an exception which 

permits a response to a documented 

request. 

Not applicable 

Figure 7 describes restrictions on the use of federal grant funds and matching grant funds for lobbying. In 

addition, IRC § 501(c)(3) organizations are subject to lobby limits (using different lobbying definitions) under 

74 
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the Internal Revenue Code. In general, an IRC § 501(c)(3) organization may conduct an insubstantial amount 

of lobbying and still maintain its tax-exempt status. See Publication 4221-PC, Compliance Guide for 501(c)(3) 

Public Charities, available at www.irs.gov/pub/irs-pdf/p4221pc.pdf. 

For example, a grant recipient may send an email to the ABA-sponsored LITC listserv to gather support or 

opposition for legislation. Although such an email attempts to influence legislation, so long as neither federal 

grant funds nor matching funds are used, the grant recipient has not violated Title 31 or Title 18 of the U.S. 

Code. If the grant recipient has a requirement under Title 31 to report lobbying activities, the email activity 

would need to be disclosed, including any research or background work performed in connection with the email 

to the listserv. For purposes of IRC § 501(c)(3), sending a single email to the listserv would likely constitute an 

“insubstantial” amount of lobbying. 

The grant recipient likely should not have substantial expenditures or have expended substantial time devoted to 

simple tasks such as sending a single email. Keep in mind that if a grant recipient anticipates devoting, or having 

volunteers devote, a large amount of time to the endeavor (e.g., researching the issue, drafting proposed legislation, 

responding to comments on the listserv about the proposal), the activity could rise to the level of being more than 

insubstantial, in which case the grant recipient may make a lobbying election under IRC § 501(h). IRC § 501(h) 

measures the permitted/prohibited level of lobbying solely by expenses. If the grant recipient employee is 

considered a full-time LITC employee, then this activity may not be undertaken during working hours. 

For more information about making a lobbying election, refer to: 

n	IRC § 501(h) and IRC § 4911; 

n	Treas. Reg. §§ 1.501(h)-1 through 1.501(h)-3; 

n	Treas. Reg. §§ 56.4911-1 through 56.4911-10; and 

n	Publication 557, Tax-Exempt Status for Your Organization. 

Clinics receiving Legal Services Corporation (LSC) funds should not confuse the above rules 

on lobbying with LSC restrictions. There may be lobbying activities that are acceptable under 

LITC guidance that are prohibited under LSC requirements and vice versa. 

E. REPORTING RESPONSIBILITIES 

Requirement to Submit Reports on Grant Activities 

The LITC Program Office requires the timely submission of two reports for each grant year – an Interim Report 

and a Year-end Report. The LITC Program Office uses the reports to assess the grant recipient’s progress in 

meeting its stated goals and objectives and to measure the quality of clinic operations, including the services 

provided to low-income and ESL taxpayers. Quality of operations is measured by determining how well grant 

recipients support the three prongs of the LITC mission and the related performance measures. The LITC 
76 LOW INCOME TAXPAYER CLINICS

Program Office also compiles and analyzes data from the reports to assess the overall success of the LITC Program. 

Data is then incorporated into Publication 5066, LITC Program Report, which reports the activities of the LITCs 

to internal and external stakeholders, including Congress, and highlights the important work that LITCs perform 

to protect the rights of America’s taxpayers. Thus, it is important that grant recipients provide accurate and 

complete reports. 

Submission of Reports and Other Documents 

Grant recipient Interim and Year-end Reports are submitted online through GrantSolutions at 

www.grantsolutions.gov. The LITC Program Office provides annual training on using GrantSolutions. These 

trainings are announced on the LITC Toolkit. 

Completing the Application Amendment Package 

Application amendments are completed and submitted in GrantSolutions after receiving an NOA indicating 

the full amount of the award. (The LITC Program Office will determine final award amounts after Congress 

appropriates funding for fiscal year 2025.) An application amendment package is required by all grant recipients, 

even if the grant recipient is not changing the budget or program performance plan. This is necessitated by the 

system software. 

The application amendment package consists of the following: 

n	Standard Form 424, Application for Federal Assistance; 

n	Form 13424, Low Income Taxpayer Clinic (LITC) Application Information; 

n	Form 13424-J, Detailed Budget Worksheet and Narrative Explanations; and 

n	Project Abstract. 

If the grant amount awarded is less than the amount of grant funds requested, the grant recipient must provide 

a revised budget (Form 13424-J) with the application amendment package. If the amount requested is received, 

then the grant recipient will resubmit the budget provided with the application. All grant recipients must submit 

Form 13424-J with the application amendment package. If the grant recipient was awarded less than the amount 

requested and the difference in the funding award affects the clinic’s proposed activities, a revised program plan 

must also be submitted. The budget or performance plan may also need to be amended because of conditions 

imposed by the LITC Program Office upon receipt of the award or if there have been any significant changes to 

the grant recipient’s operations, such as to key clinic personnel, between the time the application was submitted 

and completion of the application amendment. Changes to the program plan must be provided on the project 

abstract form. If no changes are being made to the program plan for the grant year, the grant recipient must 

indicate, “No changes to the program plan.” “Not Applicable” is not a sufficient response. 

The project abstract must also include the four numerical goals requested from all grant recipients: 

n	New representation cases to be opened in the calendar year; 

n	Consultations with low-income and ESL taxpayers; 

n	Educational activities for low-income and ESL taxpayers; and 

n	Low-income and ESL taxpayers to be reached in educational activities. 
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V

i. Events Requiring Notification to the LITC Program Office 

An award of less than the applicant’s requested funding amount is based on several factors, including the 

proposed goals in the application. The grant recipient should consult with the assigned Advocacy Analyst before 

amending the clinic’s program plan in response to receipt of less than the requested grant amount, especially when 

contemplating reductions in proposed activities and goals, to determine whether these changes are likely to be 

approved. The Program Office may also request additional information be submitted with the project abstract. 

The application amendment will also need to be revised during the grant year if there are certain enumerated 

changes discussed in Section VI.E.i., Events Requiring Notification to the LITC Program Office. Upon notification 

of the changes, the assigned Advocacy Analyst will return the application amendment package back to the grant 

recipient so the changes can be made and the package resubmitted. The Program Office will offer a training session 

about the application amendment process after NOAs are issued; the date and time will be announced on the 

LITC Toolkit. A short instructional video about completing Form 1324-J is also available on the LITC Toolkit. 

Some anticipated changes should be discussed with the LITC Program Office as far in advance of the anticipated 

change as possible, as some changes may not be allowable and/or may impact the clinic’s eligibility to draw down 

further grant funds. Changes may also have an impact on funding decisions for a pending LITC grant application. 

This section discusses some changes that a clinic may experience. To report changes or anticipated changes 

requiring advanced notice, grant recipients should contact their assigned Advocacy Analyst via email, including a 

copy to LITCProgramOffice@irs.gov. The Advocacy Analyst will respond and request a time to discuss the matter 

with the grant recipient. For items that require the grant recipient to revise the application amendment package, 

the Advocacy Analyst will return the package to the grant recipient via GrantSolutions and schedule a due date for 

resubmission. 

Changes in Entity or Sponsoring Organization 

Grant recipients must notify the LITC Program Office if the clinic or the clinic’s sponsoring organization plans 

to change its type of entity, including a merger with another clinic or organization. This notification shall inform 

the LITC Program Office of the planned entity changes or merger event, including the name and identifying 

information of any new organization involved or being formed, a timeline for the change or merger, and the name 

and contact information for the person the Program Office should contact with questions. 

If a merger occurs, the Program Office may substitute another organization for the original sponsoring organization 

but not before confirming that the substitute organization has received the original sponsoring organization’s 

assets, the substitute organization’s clinic will provide the same scope of services to the same population as serviced 

or proposed to be serviced in the grant recipient’s application, and the substitute organization is qualified under 

the relevant statutes and regulations to be an LITC grant recipient. The Program Office may not be deemed as 

approving any entity change or merger until such approval is received in writing from the Director of the LITC 

Program. The grant recipient is encouraged to notify the Program Office as early in the entity change or merger 

process as possible so the two can timely work through the issues and, hopefully, limit any lapse in funding. 

Failure to timely notify the Program Office of a potential entity change or merger may result in restriction of 

funds or suspension or termination of the grant, see Section VIII, Award Modification, Suspension, Termination, or 

Withdrawal. 
78 LOW INCOME TAXPAYER CLINICS

Significant Changes in Clinic Operations 

Grant recipients must notify the LITC Program Office with problems, delays, or adverse conditions that 

significantly affect operations of the clinic or materially impair its ability to meet the objectives of the award. 

This notification shall inform the Program Office of events, such as those described in this section, that may 

significantly affect operations and include a statement of the action taken or contemplated to address the 

situation, and whether any assistance from the Program Office is needed to resolve the situation. Failure to notify 

the Program Office may result in restriction of funds or suspension or termination of the grant, see Section VIII, 

Award Modification, Suspension, Termination, or Withdrawal. 

Changes in Clinic or Key Personnel Contact Information 

Grant recipients must immediately notify the LITC Program Office about proposed changes in contact 

information for the following: 

n	Key personnel, including the Clinic Director, QTE, or QBA (including their telephone number, mailing 

address, or email address); and 

n	Clinic address (both the physical address and the mailing address), telephone number, or fax number. 

These notifications ensure that the LITC Program Office has the most up-to-date information for each clinic and 

can also update information in IRS online resources and printed publications. 

Changes in Program Plan or Budget Under 2 CFR § 200.308 

Grant recipients are expected to spend grant funds and matching funds in accordance with the program plan and 

budget submitted with their application, or as later revised and approved. Grant recipients must request approval 

from the LITC Program Office for any substantial change in the program plan or budget. A substantial change in 

the program plan or budget includes a change to: 

n	The scope or objective of the program; 

n	The days and hours of operation; 

n	The beginning and ending dates clinic services will be provided; 

n	Key personnel or time devoted to the LITC by key personnel; and 

n	The amount or composition of matching funds (cash or third-party in-kind match). 

Grant recipients are responsible for monitoring the use of LITC grant funds throughout the year to ensure that 

all grant funds awarded will be expended. If a grant recipient determines that it will have unused grant funds 

(i.e., not spend its entire award), the grant recipient should immediately notify the assigned Advocacy Analyst in 

writing. The notification should contain the following information: 

n	The amount of grant funds being returned; 

n	The reason for the return of funds; and 

n	The impact the return of funds will have on future operations (e.g., this is a one-time occurrence or the grant 

recipient anticipates a permanent reduction in its future funding needs). 
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V

A grant recipient that does not expect to use its entire grant award must contact the LITC Program Office 

immediately so the Program Office will have sufficient time to re-obligate the funds to another clinic by 

September 30, the end of the federal government’s fiscal year. Grant recipients should also include this information 

in the Interim Report if they become aware that they will not use all funds prior to submitting the report. 

Withdrawal From the LITC Program 

A grant recipient that wishes to withdraw from the LITC Program or terminate operations of its LITC must 

notify the LITC Program Office prior to the date of withdrawal or termination. This notice should be given as far 

in advance as possible. Advance notice will allow the Program Office to contact community partners where the 

clinic was located to find an alternate organization to apply for grant funding and hopefully ensure the ongoing 

availability of LITC services in that area. 

NOTE: Upon withdrawal from the LITC Program, an organization may no longer refer to itself as an LITC. 

Failure to abide by this prohibition could lead to civil/criminal penalties or imprisonment. See 31 U.S.C. § 333. 

ii. Submitting the Interim Report* 

An Interim Report must be submitted through GrantSolutions by July 31, 2025. The Interim Report covers the 

first half of the grant year (January 1, 2025 through June 30, 2025) and consists of the following items, prepared 

in accordance with the instructions: 

n	Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report; 

n	Form 13424-K, Low Income Taxpayer Clinic (LITC) Case Information Report; 

n	Form 13424-L, Statement of Grant Expenditures and Narrative Explanations; and 

n	Form 13424-N, Low Income Taxpayer Clinic (LITC) Program Narrative Report. 

Clinics no longer submit the following forms as a part of the Interim Report but will continue to track data and 

submit these forms with the Year-end Report: 

n	Standard Form 425, Federal Financial Report; 

n	Form 13424-B, Low Income Taxpayer Clinic (LITC) Case Issues Report; and 

n	Form 13424-C, Low Income Taxpayer Clinic (LITC) Advocacy Information Report. 

* If you operated an ESL Education Pilot Program only, you are required to submit the following at interim: 


Form 13424-A (excluding sections 6-10), Form 13424-L, and Form 13424-N (excluding section 2.v-2.vii). 


If the clinic provided any consultations or casework assistance during the grant year, then all forms need to be 


completed in their entirety.
 

For reference, copies of all required reporting forms and instructions are included in Appendix B. However, grant 

recipients must complete and submit reporting forms in GrantSolutions. If not completing an entry on one of the 

forms results in a GrantSolutions submission error, list N/A to address the issue. 
80 LOW INCOME TAXPAYER CLINICS

iii. Submitting the Year-end Report* 

A Year-end Report must be submitted online through GrantSolutions by March 31, 2026. The Year-end Report 

covers the entire grant year (January 1, 2025 through December 31, 2025), with one exception. See Form 

13424-N in the list below. A complete Year-end Report consists of the following items, prepared in accordance 

with the instructions: 

n	Standard Form 425, Federal Financial Report; 

n	Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report; 

n	Form 13424-B, Low Income Taxpayer Clinic (LITC) Case Issues Report; 

n	Form 13424-C, Low Income Taxpayer Clinic (LITC) Advocacy Information Report; 

n	Form 13424-K, Low Income Taxpayer Clinic (LITC) Case Information Report; 

n	Form 13424-L, Statement of Grant Expenditures and Narrative Explanations; and 

n	Form 13424-N, Low Income Taxpayer Clinic (LITC) Program Narrative Report. For sections 3 & 4, report 

emerging issues and success stories from the second half of the year only. 

Subject to OMB approval, the LITC Program Office may require additional reporting information from LITCs. 

Grant recipients should refer to the LITC Toolkit for updates on reporting requirements prior to submitting their 

reports. Training sessions will be offered to all grant recipients in advance of when each report is due, and details 

for the sessions will be announced on the LITC Toolkit. 

* If you operated an ESL Education Pilot Program only, you are required to submit the following at interim and 

year-end: Standard Form 425, Form 13424-A (excluding sections 6-10), Form 13424-C, Form 13424-L, and 

Form 13424-N (excluding section 2.v-2.vii). If the clinic provided any consultations or casework assistance during 

the grant year, then all forms need to be completed in their entirety. 

Late Submissions 

In certain instances, grant recipients may request an extension of time to submit the Interim or Year-end Report. 

However, a report will still be considered late if submitted after the due date, notwithstanding any extension 

that may be granted. The request must be submitted in writing to the LITC Program Office before the due date 

of the report and must include an explanation justifying the extension and the date by which the report will 

be submitted. Grant recipients should contact their assigned Advocacy Analyst via email, including a copy to 

LITCProgramOffice@irs.gov, to submit an extension request. Failure to timely submit required reports to the 

LITC Program Office may result in any or all the following: 

n	Restricted access to grant funds; 

n	Suspension or termination of the grant; or 

n	Reduction of any future award amount. 
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V

iv. Grant Closeout 

The LITC Program Office will close out the LITC grant award when it determines that all applicable 

administrative actions and activities related to the grant have been completed by the grant recipient. Before a grant 

may be closed out, the following actions must be completed per 2 CFR § 200.344: 

n	Submission by the grant recipient of all required Interim and Year-end Report forms; 

n	Liquidation by the grant recipient of all obligations incurred under the award no later than 120 calendar 

days (unless the LITC Program Office authorizes an extension) after the end date of the period of 

performance; 

n	Draw down by the grant recipient of payment for all allowable reimbursable costs; 

n	Repayment by the grant recipient of any balances of unobligated cash drawn down by the grant recipient; 

and 

n	Settlement of any adjustments to the grant award to account for any shortfall in the dollar-for-dollar 

matching funds requirement. 

The Program Office must make every effort to complete closeout actions no later than one year after the end of 

the period of performance. If the grant recipient fails to complete the requirements to close out, the Program 

Office will close out the award with the information available. If the grant recipient does not submit all required 

reports and forms within one year of the period of performance end date, the LITC Program Office must report 

the grant recipient’s material failure to comply with the terms and conditions of the award with the OMBdesignated integrity and performance system (FAPIIS). Per 2 CFR § 200.339, other enforcement actions may also 

be pursued at the discretion of the Program Office. 

By accepting the NOA, the grant recipient authorizes the LITC Program Office to take steps to de-obligate 

funds without the need for the grant recipient to execute a new NOA, budget, or reporting forms if the amount 

involved is less than $25. The Program Office will notify the clinic via email of the planned action 30 days prior 

to taking the action, and a de-obligation will not be initiated any earlier than September 1 of the year following 

the close of the budget period. 
LOW INCOME TAXPAYER CLINICS

VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND 

CONTACT 

The LITC Program Office manages and administers the LITC grant program to ensure federal funding is 

expended and funded programs are implemented in full accordance with U.S. statutory and public policy 

requirements. The LITC Program Office fulfills its responsibilities by: 

n	Administering the award and payment of grant funds; 

n	Providing assistance and guidance to grant recipients; and 

n	Monitoring the performance of grant recipients. 

A. STRUCTURE 

The LITC Program Office is part of TAS. The Director of the LITC Program reports directly to the National 

Taxpayer Advocate. The LITC Program Office staff consists of: 

n	Headquarters staff, including managers, program analysts, technical advisors, budget analysts, and support 

staff who report to the Director of the LITC Program and have program-wide responsibilities, including 

Program Office and clinic financial matters; 

n	Operations Office staff, including analysts responsible for processing grant applications, awards, reports, and 

payments; and 

n	Advocacy Office staff, including analysts responsible for reviewing and analyzing clinic reports, conducting 

site assistance visits, and serving as the primary liaison between grant recipients and the LITC Program 

Office. 

Figure 8, LITC Program Office Staffing Chart 

Advocacy 

Manager 

Operations 

Manager 

Director 

Analyst Analyst Analyst Analyst Analyst Analyst Analyst Analyst Analyst Budget

Analyst

Budget

Analyst

Budget

Analyst Analyst Analyst

Senior 

Analyst Analyst Secretary Technical
 Advisor 

Technical
 

Advisor 

82 
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VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT VI I II III IV

V

B. ADMINISTRATION 

The LITC Program Office administers the grant by: 

n	Processing LITC grant applications and making awards to successful applicants; 

n	Revising and issuing annually Publication 3319, LITC Grant Application Package and Guidelines; 

n	Maintaining the LITC Toolkit, a password-protected website used to disseminate program guidance and 

provide resources to assist clinics in assisting low-income and ESL taxpayers; 

n	Maintaining Publication 4134, Low Income Taxpayer Clinic List, a list of all federally-funded LITCs, and 

ensuring that the publication is included in IRS mailings, referenced in IRS publications and notices, and 

available at TACs; 

n	Updating information about the LITC Program on IRS and TAS websites, including an interactive LITC 

finder tool on https://www.taxpayeradvocate.irs.gov/about-us/low-income-taxpayer-clinics-litc/; 

n	Publishing annually Publication 5066, LITC Program Report, which reports the activities of the LITCs to 

internal and external stakeholders; and 

n	Reviewing and analyzing data from reports submitted by grant recipients to identify trends and recognize 

best practices. 

The LITC Program Office assists by: 

C. ASSISTANCE 

n	Providing technical assistance and guidance to grant recipients and potential applicants; 

n	Informing the public about the availability of LITCs, to the extent permitted by law; 

n	Sponsoring and organizing the Annual LITC Grantee Conference to deliver instruction and continuing 

education to all grant recipients and provides an opportunity for attendees to connect with colleagues from 

LITCs throughout the country to share ideas and strategies to better assist low-income and ESL taxpayers; 

n	Conducting orientation visits to familiarize new grant recipients with LITC Program requirements and to 

identify potential areas where the clinic may need to create systems or improve processes; 

n	Fostering the working relationship between grant recipients and LTA offices; 

n	Issuing special appearance authorizations to LITCs that permit students and law graduates working under 

the supervision of a practitioner to represent taxpayers before the IRS; 

n	Coordinating grant recipients’ access to e-Services products offered by the IRS; and 

n	Assisting with resolution of problems that grant recipients may experience with GrantSolutions. 

D. OVERSIGHT 

The LITC Program Office conducts oversight of grant recipients by: 

n	Reviewing Interim and Year-end Reports to assess grant recipients’ progress in meeting program goals, 

collecting emerging issues identified, and aggregating performance data submitted by grant recipients; 
84 LOW INCOME TAXPAYER CLINICS

n	Reviewing budgets and financial reports submitted by grant recipients to ensure that federal funds are 

properly expended and that matching funds are properly sourced, spent, and valued; and 

n	Conducting operational review visits to interview clinic personnel, observe facilities, review procedures and 

internal controls, corroborate report information, and evaluate operations. 

E. SITE ASSISTANCE VISITS 

The LITC Program Office or the LTA conducts a site assistance visit to each grant recipient every year. There are 

three types of site assistance visits: 

n	Orientation visit; 

n	Operational review visit; and 

n	LTA visit. 

Orientation Visits 

The LITC Program Office conducts an orientation visit to each grant recipient that did not receive a grant in the 

preceding year. The orientation visit will generally occur during the first 120 days of the grant year. An orientation 

visit provides an opportunity to familiarize a new grant recipient with LITC Program requirements and to measure 

the progress of its startup activities. During the visit, the staff of the LITC Program Office will discuss accounting 

procedures and internal controls with the new grant recipient and perform a limited sampling of records and 

expense documentation to ensure that the controls are in place and being used appropriately. The orientation 

visit also allows the staff to assess the status of newly funded clinics and to identify potential areas where the grant 

recipient may need to create systems or improve processes to meet the requirements of the LITC Program. 

During the orientation visit, discussions about the clinic’s finances will incorporate accounting and financial 

controls as documented on the pre-visit assessment/site visit plan prepared by the Advocacy Analyst prior to the 

visit. Specifically, the Program Office reviews at least one receipt and invoice at random and other supporting 

documentation, including approvals and reimbursements for the LITC conference travel, if available. In addition, 

LITC Program Office staff samples at random personnel expenses, if any, from the first quarter of the current 

grant year. As there will be no report for comparison, the primary purpose of this sampling provides a basis for 

discussing financial recordkeeping and determine how well the clinic is following policies and procedures. 

Operational Review Visits 

The purpose of an operational review visit is to evaluate a clinic’s overall operations and to provide technical 

assistance to help the grant recipient maintain compliance with the terms and conditions of the LITC grant. 

The visit may include the review of documents, papers, or other records of the grant recipient. OMB regulations 

require that the IRS must have the right to access any documents, papers, or other records of a grant recipient 

pertinent to the award to make audits and examinations. See 2 CFR § 200.337(a). The Treasury Department 

implemented a regulation making it clear that “[t]he right of access under 2 CFR § 200.337 shall not extend to 

client information held by attorneys or federally authorized tax practitioners under the Low Income Taxpayer 

Clinic program.” See 2 CFR § 1000.337. When monitoring and evaluating clinic activities, the LITC Program 
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V

Office will respect the clinic’s duty to protect confidential information and will not interfere with the confidential 

nature of the relationship between qualified representatives and their clients. Therefore, the LITC Program 

Office will not require LITCs to provide access to taxpayer-specific information for auditing or verifying that the 

90/250 requirement has been satisfied, or that the amounts in controversy generally do not exceed the amount 

specified in IRC § 7463. In addition, the LITC Program Office will not require an LITC to provide access to 

information a taxpayer provided to the LITC during a consultation that did not result in the taxpayer executing a 

representation agreement. Prior to an operational review visit, however, the assigned Advocacy Analyst will require 

the clinic to complete an LITC Site Assistance Visit – Case Eligibility Requirements Tracking Form to collect 

data on eligibility decisions made by the clinic during the grant year but does not request any taxpayer identifying 

information such as taxpayer names or identification numbers. 

If the LITC Program Office identifies a concern with a clinic’s procedure for collecting financial eligibility 

or amount in controversy information and making eligibility determinations, the LITC Program Office staff 

member conducting an operational review visit may decide to randomly sample the financial eligibility or amount 

in controversy determinations made by the clinic staff. This will be done by asking the clinic to generate a list 

of cases accepted for representation by a unique identifier for the timeframe that is under review. The unique 

identifier should not be the taxpayer’s name or taxpayer identification number. Using a clinic staff member as 

an intermediary, the LITC Program Office staff visiting will randomly select a few cases to review and will ask 

the intermediary to pull the case file information. The LITC Program Office staff will then ask the intermediary 

to answer questions about what is recorded for the applicant, including the household composition, household 

income, and the amount in controversy. 

During an operational review visit, the grant recipient’s assigned Advocacy Analyst will interview clinic personnel, 

examine intake procedures, review case management and reporting systems, and sample financial records. An 

operational review visit may also include observation of clinic facilities and review of procedures and internal 

controls, personnel policies, training plans, privacy and confidentiality policies, outreach plans and materials, 

educational curricula, fee policies, and client satisfaction instruments. 

By supporting and monitoring the work of LITCs, the Program Office staff builds a relationship with clinicians 

to create trust and encourage the LITCs to seek guidance and assistance from the Program Office. Generally, the 

Program Office will visit each LITC at least once every three years. The Program Office may visit at any time and 

more often if an assessment of the clinic indicates that more close monitoring is necessary and best accomplished 

by additional visits. 

Local Taxpayer Advocate Visits 

The LTA assigned to a clinic must visit at least once a year. If the LTA participates in a visit with the Program 

Office, the LTA will be provided with time during the visit to discuss current issues, collaborations, or other 

topics of mutual interest. In a year when the LTA does not accompany the LITC Program Office on an 

orientation visit or an operational review visit, the LTA must conduct an LTA visit. The purpose of the LTA 

visit is to foster the relationship between the LTA’s office and the clinic by providing an opportunity to share 

emerging case issues and ideas to collaborate on joint education and outreach activities. 
LOW INCOME TAXPAYER CLINICS

F. CONTACTING THE LITC PROGRAM OFFICE

8:00 a.m. - 4:30 p.m. ET Mon. - Fri. 

202-317-4700 

877-477-3520 

Potential applicants may direct questions concerning the LITC Program or

 the application process to the LITC Program Office. Organizations that have been awarded 

an LITC grant should contact their assigned Advocacy Analyst directly with 

questions regarding reporting or program requirements 

Hours of Operation 

Phone 

E Fax 

Email LITCProgramOffice@irs.gov 

Address 

Internal Revenue Service 

LITC Program Office 

Attention: TA: LITC, Room 1034 

1111 Constitution Ave., NW 

Washington, DC 20224 

For questions relating to Special Appearance Authorizations for Student 

and Law Graduate Practice 

Hours of Operation 8:00 a.m. - 4:30 p.m. ET Mon. - Fri. 

Phone 212-298-2052 

E Fax 877-477-3520 

OTHER RESOURCES

www.grants.gov 

800-518-4726 

System for Award Management (SAM.gov) 

Website www.sam.gov 

Phone Support 866-606-8220 

Submission of a Full Grant Application via Grants.gov 

Website 

Phone Support 

Email Support support@grants.gov 

Submission of an NCC Request and Interim/Year-end Reports via GrantSolutions 

Website www.GrantSolutions.gov 

Email Support Michael.J.Condict@irs.gov 

86 
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VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT VI I II III IV

V

 

www.irs.gov/about-irs/your-civil-rights-are-protected 

https://pms.psc.gov/ 

877-614-5533 

PMSSupport@psc.gov 

Department of Health and Human Services (HHS) Payment Management System (PMS) 

Website 

Phone Support 

Email Support 

Civil Rights Protection 

Website 

2 CFR Part 200 (OMB Guidance) and 

2 CFR Part 1000 (Treasury Department Adoption of OMB Guidance) 

Website 

www.ecfr.gov 

There are also FAQs about 2 CFR Part 200 available at: 

2 CFR-FrequentlyAskedQuestions_2021050321.pdf (cfo.gov) 

Taxpayer Advocate Service Website 

Website www.taxpayeradvocate.irs.gov 

United States Tax Court 

Website www.ustaxcourt.gov 

Information and Updates 

LITC eligibility, Program 

Report, and locations 

https://www.taxpayeradvocate.irs.gov/about-us/low-income-taxpayerclinics-litc/ 

LITC Toolkit 

www.litctoolkit.com 

(Access restricted to current LITC grant recipients) 

LITC Program Publications 

Publication 3319, LITC Grant Application Package and Guidelines 

Publication 4134, Low Income Taxpayer Clinic List 

Publication 5066, Low Income Taxpayer Clinic (LITC) Program Report 

87 
88 LOW INCOME TAXPAYER CLINICS

 

 

VIII.AWARD MODIFICATION, SUSPENSION, 

TERMINATION, OR WITHDRAWAL 

The LITC Program Office’s duty to enforce grant recipient compliance as a condition of funding is vitally 

important. The LITC Program Office may become aware of clinics’ non-compliance through reviews of 

clinic reports, site assistance visits, or other interactions with grant recipients. If the clinic fails to meet its 

obligations under the terms and conditions of the grant, the LITC Program Office may reduce an award 

amount, delay release of funds, or suspend or terminate a grant in whole or in part. Prior to taking such steps, 

the IRS will determine whether imposing additional conditions upon the grant recipient is likely to remedy the 

non-compliance. A grant award may also be terminated with the consent of the grant recipient, in which case the 

two parties must agree upon the termination conditions, including the effective date and, in the case of partial 

termination, the portion to be terminated. Notwithstanding that a multiyear grant has been awarded under 

IRC § 7526(c)(3), the IRS may terminate a grant during the multiyear period. 

Actions that may lead to a reduced award, delay in receiving grant funds, suspension, or termination include: 

n	Failure to comply with federal tax and nontax obligations, or the applicant does not have an active SAM 

registration or is suspended or debarred; 

n	Failure to satisfy the 90/250 requirement of IRC § 7526(b)(1)(B)(i); 

n	Failure to provide matching funds on a dollar-for-dollar basis for all LITC grant funds awarded; 

n	A violation by the grant recipient of a material provision of IRC § 7526 or other applicable law or regulation 

(including the Uniform Guidance); 

n	A violation by the grant recipient of a material provision of the Publication 3319, LITC Grant Application 

Package and Guidelines (for example, failure to timely file complete and accurate reports); 

n	Failure to maintain taxpayer information in a secure manner; and 

n	Failure to provide accurate and competent representation to taxpayers, where competent representation 

requires the legal knowledge, skill, thoroughness, and preparation reasonably necessary to provide effective 

assistance. See ABA Model Rule 1.1, Competence, and Model Rule 1.3, Diligence. 

NOTE: 2 CFR § 200.340 strengthens the ability of the LITC Program Office to terminate federal awards, to the 

greatest extent authorized by law, when the federal award no longer effectuates the program goals. 

Remedies for Noncompliance 

If a grant recipient violates the federal statutes, regulations, or the terms and conditions in the Notice Award, the 

LITC Program Office may impose additional conditions, as described in 2 CFR § 200.208. If the LITC Program 

Office determines that noncompliance cannot be remedied by imposing additional conditions, the LITC Program 

Office may take one or more of the following actions, as appropriate in the circumstances: 

n	Temporarily restrict access to grant funds pending correction of the noncompliance or more severe 

enforcement action; 

n	Disallow all or part of certain cost items, including grant expenditures and matching funds, that support the 

activity or action not in compliance and seek recovery of improperly spent funds (plus any interest); 

n	Wholly or partly suspend or terminate the grant; 
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VIII. AWARD SUSPENSION OR TERMINATION VII VI I II III IV

V

n	Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180; 

n	Withhold a future award amount; or 

n	Take other remedies that may be legally available. 

Notification of Grant Suspension or Termination 

Suspension or termination of a grant award will be handled in accordance with the Uniform Guidance. The LITC 

Program Office will notify the grant recipient in writing of any suspension or termination action, setting forth the 

reasons for such action and the effective date. The notification will advise the grant recipient of its right to object 

to the suspension or termination action by providing information and documentation in writing to challenge the 

basis for the action. 

Challenging a Suspension or Termination 

If a grant recipient wishes to challenge the LITC Program Office’s decision to suspend or terminate a grant, 

it must send a written request to the Director of the LITC Program for reconsideration of the suspension or 

termination decision. The grant recipient may provide information and documentation for review during the 

reconsideration. The Director of the LITC Program will review the submission and make a recommendation to 

the National Taxpayer Advocate, who has final decision making authority, unless recused. In recusal situations, a 

final decision will be made by the Deputy National Taxpayer Advocate. 

IRC § 7526 does not require the IRS to provide grant recipients an opportunity for a hearing or an appeal. 

Therefore, the necessity for renegotiation, suspension, or termination of a grant agreement will be determined 

solely by the IRS. The decision of the National Taxpayer Advocate (or the Deputy National Taxpayer Advocate in 

recusal situations) when an LITC challenges the Program Office’s decision is final. 

Responsibilities Following Termination or Withdrawal 

If the LITC Program Office terminates a grant, the grant recipient must submit a final Year-end Report to the 

LITC Program Office within 90 days of the termination. Similarly, if clinic activity is terminated prior to the 

expiration of the period of the grant agreement or if a grant recipient withdraws from the LITC Program, a final 

Year-end report must be submitted within 90 days of final clinic activity or withdrawal from the LITC Program. 

All unused funds must be repaid to the IRS within 30 days of the date of withdrawal or the date of termination. 

The federal government is generally obligated to charge interest on any amount not repaid promptly. See 

31 CFR § 901.9. Thus, for any funds the LITC Program Office requests to be returned to the IRS, failure to 

repay those funds on time may result in the grant recipient having to pay interest on those funds. 

Employees and volunteers of the clinic who are lawyers must adhere to their responsibilities as attorneys, not just 

the responsibilities within the parameters of the LITC Program. The ABA has model rules of professional conduct 

that are applicable when a lawyer is terminating representation. ABA Model Rule 1.16 provides that upon 

terminating representation of a client, a lawyer must take reasonable steps to protect a client’s interests, which 

includes giving notice to the client, allowing the client time to find other representation, and returning papers and 

property to the client. The state bar may have a similar rule of professional responsibility that provides guidance 

for terminating representation. Courts, such as the U.S. Tax Court, require the filing of a motion for leave to 
LOW INCOME TAXPAYER CLINICS

withdraw as counsel. See U.S. Tax Court Rule 24. In addition, if the clinic will no longer participate in the U.S. 

Tax Court Clinical Program (including the Calendar Calls), the clinic must notify the Tax Court so it will cease 

referring taxpayers to that clinic. 

Use of “LITC” After Discontinuation of Services 

Once an organization is no longer a grant recipient, the clinic must not use “LITC” as part of its name. 

Circular 230 prohibits practitioners from providing misleading or deceptive statements or claims. See 

31 CFR § 10.30(a)(1). If the organization will continue to exist but will not be receiving grant funds, it may be 

misleading for the organization to call itself an LITC. Further, use of the LITC logo or LITC designation may 

lead to civil/criminal penalties or imprisonment. See 31 U.S.C. § 333. In appropriate circumstances, the LITC 

Program Office may need to refer the matter to the IRS’s Office of Professional Responsibility and/or the Treasury 

Inspector General for Tax Administration. 

Paperwork Reduction Act Notice 

This application package and guidance document is provided for awards under the Low Income Taxpayer Clinic 

Grant Program. The information is requested from the applicants to determine their eligibility for an LITC grant 

and evaluate their grant proposals. Information is also requested from all grant recipients for progress monitoring 

purposes. Applicants do not have to respond to this collection of information unless it displays a valid OMB 

number. Books or records relating to a form or its instructions must be retained as long as their content may 

become material in the administration of any Internal Revenue law. Five hours are included for reviewing this 

publication and the different sources cited therein, as well as the various assurances and certifications which 

are part of the application process. The time needed to complete and file these forms will vary depending on 

individual circumstances. The estimated average times for the forms are: 

13424 20 minutes 

13424-A 2 hours 

13424-B 3 hours 

13424-C 30 minutes 

13424-J 1 hour, 30 minutes 

13424-K 3 hours 

13424-L 1 hour, 30 minutes 

13424-M 5 hours 

13424-N 1 hour, 30 minutes 

424 * 

425 * 

Project Abstract 30 minutes 

Form Number Time Burden 

90 
LOW INCOME TAXPAYER CLINICS 91 

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VIII. AWARD SUSPENSION OR TERMINATION VII VI I II III IV

V

Comments concerning the accuracy of these time estimates or suggestions for reducing the burden may be 

sent to Internal Revenue Service, Tax Forms and Publications Division, 1111 Constitution Ave. NW, IR-6526, 

Washington, DC 20224 or at Comment on Tax Forms and Publications | Internal Revenue Service (irs.gov). Do 

not send grant application forms to this address. Full Grant Applications must be submitted through Grants.gov 

and NCC Requests must be submitted through GrantSolutions. General comments about the application package 

should be sent to the Internal Revenue Service, Taxpayer Advocate Service, LITC Program Office, TA:LITC, 1111 

Constitution Ave., NW, Washington, DC 20224. 

Catalog of Federal Domestic Assistance Number: 21.008, OMB Approval No.1545-1648. 

* These forms have individual OMB approval numbers and established time burdens, Standard Form 424, 

Application for Federal Assistance (OMB No. 4040-0004) and Standard Form 425, Federal Financial Report 

(OMB No. 4040-0014). 
92 LOW INCOME TAXPAYER CLINICS

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LOW INCOME TAXPAYER CLINICS 93 

VII I II III IV

V VI APPENDIX A GLOSSARY INDEX

 

APPENDIX A 

FULL GRANT APPLICATION FORMS 

AND NON-COMPETING CONTINUATION 

REQUEST FORMS 
94 LOW INCOME TAXPAYER CLINICS

GRANT APPLICATION FORMS1 

To be considered for 2025 LITC Program grant funding, all LITC Full Grant Applications and Non-Competing 

Continuation (NCC) Requests must be submitted by 11:59 p.m. (Eastern Time) on June 12, 2024. The Funding 

Opportunity Number for the 2025 LITC grant is TREAS-GRANTS-042025-001. 

The forms contained in this publication are provided for reference purposes only. All grant applications must be 

submitted electronically. Full Grant Applications must be submitted via Grants.gov and NCC Requests must be 

submitted via GrantSolutions. 

Any forms submitted with a Full Grant Application or NCC Request may be released under the Freedom of 

Information Act (FOIA). In response to a FOIA request, the LITC Program Office will release these forms after 

appropriate redactions to ensure confidentiality of taxpayer information. 

If you have questions about the LITC Program or grant application process, please contact the LITC Program 

Office at 202-317-4700 or by email at LITCProgramOffice@irs.gov. 

Full Grant Application Forms 

A complete LITC Full Grant Application consists of the following items, submitted through Grants.gov and 

prepared in accordance with the instructions: 

q	Standard Form 424, Application for Federal Assistance 

n	NOTE: Be sure to submit required attachment for item 14 (areas affected by project - counties covered) 

and other attachments as may be needed. 

q	IRS Form 13424, Low Income Taxpayer Clinic (LITC) Application Information 

q	IRS Form 13424-J, Detailed Budget Worksheet and Narrative Explanations 

q	IRS Form 13424-M, Low Income Taxpayer Clinic (LITC) Application Narrative 

q	Attachments Form, which is part of the downloadable PDF from Grants.gov and must be used to submit 

the following items: 

n	A list of the counties covered, see Form 424, item 14 

n	Tax exempt determination letter, if applicable 

n	Proof of academic accreditation, if applicable 

n	Most recent audited financial statement (if the applicant expends $1,000,000 or more in federal funds 

during the applicant’s fiscal year, this must be a single audit or program-specific audit as required by 

2 CFR § 200.501). If the applicant’s most recent audited financial statement is available on the Federal 

Audit Clearinghouse (FAC) found at https://harvester.census.gov/facweb/, in lieu of attaching the audit, 

check the “yes” box located on Form 13424-M in response to question II.4.ii. See Section IV.E.iv, OMB 

Audit Requirement. 

n	An applicant that does not have audited financial statements must submit unaudited statements 

for its most recent fiscal year and include a statement as to why audited financial statements are not 

available on Form 13424-M in response to question II,4,iv. 

1 Where form instructions differ from guidance found in this publication, please follow the Publication 3319 guidance. 
LOW INCOME TAXPAYER CLINICS 95 

APPENDIX A

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V VI APPENDIX A GLOSSARY INDEX

 

n	Documentation (e.g., articles of incorporation or an IRS Form 2848, Power of Attorney and 

Declaration of Representative) showing the designated Tax Compliance Officer (TCO) on Form 13424 

is properly authorized to receive federal tax information 

n	Indirect cost rate agreement, if applicable 

Non-Competing Continuation Request Forms 

A complete NCC Request consists of the following items, submitted through GrantSolutions and prepared in 

accordance with the instructions: 

q	Standard Form 424, Application for Federal Assistance 

n	NOTE: Be sure to submit required attachment for item 14 (areas affected by project - counties covered) 

and other attachments as may be needed. 

q	IRS Form 13424, Low Income Taxpayer Clinic (LITC) Application Information 

q	IRS Form 13424-J, Detailed Budget Worksheet and Narrative Explanations 

q	Project Abstract, which includes the following information: 

n	Numerical goals 

n	Changes to the program plan 

n	Civil Rights Review responses 

n	Statement about availability of the audit on the Federal Audit Clearinghouse (FAC), if necessary 

q	Attachments 

n	Most recent audited financial statement (if the applicant expends $1,000,000 or more in federal funds 

during the applicant’s fiscal year, this must be a single audit or program-specific audit as required by 

2 CFR § 200.501). If the applicant’s most recent audited financial statement is available from the FAC 

found at https://harvester.census.gov/facweb/, in lieu of attaching it, include a statement about its 

availability from the FAC on the Project Abstract. See Section IV.E.iv, OMB Audit Requirement. 

n	For an applicant that does not have audited financial statements, an unaudited statement for its 

most recent fiscal year and a statement on the Project Abstract as to why an audited financial 

statement is not available 

n	Documentation (e.g., articles of incorporation or an IRS Form 2848, Power of Attorney and 

Declaration of Representative) indicating that the designated TCO on Form 13424 is properly 

authorized to receive federal tax information 

n	Indirect cost rate agreement, if applicable 

NOTE: Several years ago, GrantSolutions made changes to enhance the grant recipient user experience. NCC 

Request forms can now be completed in the new experience. 
96 LOW INCOME TAXPAYER CLINICS

INSTRUCTIONS FOR STANDARD FORM 424, APPLICATION FOR 

FEDERAL ASSISTANCE 

This is a standard form required to be submitted with all Full Grant Applications and NCC Requests. This form is 

used to report information about the applicant, including the amount and period of the grant requested, and the 

counties and congressional districts where the applicant will provide assistance. 

Signing Standard Form 424, Application for Federal Assistance, certifies that the applicant: 

q	Has provided true, complete, and accurate information; 

q	Has provided the required assurances, found in Publication 3319, Section VI.D, National Policy 

Requirements and Administrative Requirements; and 

q	Upon acceptance of an award, agrees to comply with the terms of Publication 3319, Grant Application 

Package and Guidelines, and any additional terms contained in the Notice of Award issued by the LITC 

Program Office. 

OMB requires Standard Form 424, Application for Federal Assistance, to be used by all federal grant programs. 

Some information collected on this form is not required to apply for an LITC grant; however, to ensure successful 

processing of this form, a response must be entered for each field. The instructions in this appendix indicate the 

fields in which to enter a response of N/A. 

All organizations submitting a Full Grant Application or NCC Request must complete this form. 
LOW INCOME TAXPAYER CLINICS 97

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VII I II III IV

V VI APPENDIX A GLOSSARY INDEX

 

Specific Instructions

Instructions for completing each question for a Full Grant Application or an NCC Request are incorporated into 

the sample Standard Form 424 below. Some entries may be pre-populated as indicated.
LOW INCOME TAXPAYER CLINICS

Item Field Name Information 

8(c). Organizational UEI: (Required) Enter the organizational Unique Entity Identifier (UEI) received from GSA via the 

SAM.gov system. 

8(d). Address: (Required) 

Enter the same address of the applicant organization that is in the SAM.gov system.
‚

Please provide a complete response, including: Street 1 (Required); City (Required); County/
‚

Parish; State (Required if country is U.S.); Province; Country (Required); 

9-digit Zip/Postal Code (Required).
‚

8(e). Organizational Unit: Enter N/A into this field. 

8(f). Name and contact information 

of person to be contacted 

on matters involving this 

application: 

(Required) 

Enter the First Name and Last Name (Required); Prefix; Middle Name; Suffix; Title; Add 

Organizational Affiliation (N/A); Telephone Number (Required); Fax Number; and Email 

(Required). Please provide the best possible contact information for LITC Program Office 

staff to be able to reach the appropriate individual to resolve issues with the application. 

98 
LOW INCOME TAXPAYER CLINICS 99 

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V VI APPENDIX A GLOSSARY INDEX

 

 

 

 

 

Item Field Name Information 

9. Type of Applicant: (Required) Select up to three applicant type(s). 

A. State Government 

B. County Government 

C. City or Township Government 

D. Special District Government 

E. Regional Organization 

F. U.S. Territory or Possession 

G. Independent School District 

H. Public/State Controlled Institution of Higher Education 

I. Indian/Native American Tribal Government (Federally Recognized) 

J. Indian/Native American Tribal Government (Other than Federally Recognized) 

K. Indian/Native American Tribally Designated Organization 

L. Public/Indian Housing 

M. Nonprofit with 501(c) status 

N. Nonprofit without 501(c) status 

O. Private Institution of Higher Education 

P. Individual 

Q. For-Profit Organization (Other than Small Business) 

R. Small Business 

S. Hispanic-serving Institution 

T. Historically Black Colleges and Universities (HBCUs) 

U. Tribally Controlled Colleges and Universities (TCCUs) 

V. Alaska Native and Native Hawaiian Serving Institutions 

W. Non-U.S. Entity 

X. Other (specify) 

10. Name of Federal Agency: (Required) Enter Internal Revenue Service. 

11. Catalog of Federal Domestic 

Assistance Number/Title: 

Enter 21.008 as the Catalog of Federal Domestic Assistance Number and 

Low Income Taxpayer Clinic as the title. 

12. Funding Opportunity Number/ 

Title: 

Both fields will prepopulate with the necessary information and cannot be edited. The 

information will be TREAS-GRANTS-042025-001 for the Funding Opportunity Number and 

Low Income Taxpayer Clinic as the title. 
LOW INCOME TAXPAYER CLINICS

’

Item Field Name Information 

13. Competition Identification 

Number/Title: 

This field will prepopulate with the necessary information and cannot be edited. The 

information will be TREAS-GRANTS-042025-001 as the Competition Identification Number. 

14. Areas Affected By Project: (Required) 

Add an attachment listing the areas affected, which must be reported at the county level. 

If the applicant defines service area by city or region (e.g., northwest region of the state), 

list all counties by name within the geographical bounds of the region. If the clinic serves 

the entire state, list the state and note “All Counties.” If coverage includes multiple states, 

list each state separately and “All Counties” or if not serving an entire state, list all counties 

served by name within the state. 

15. Descriptive Title of Applicant s 

Project: 

(Required) 

Enter the following:
‚

The Clinic will work to meet the goal of delivering a three-prong program to represent, 

educate and advocate for low-income taxpayers and for taxpayers for whom English is a 

second language. 

16. Congressional Districts Of 

Applicant and Program/Project: 

(Required) 

16(a). Enter the applicant’s congressional district where the sponsoring organization is 

located. 

16(b). Enter all district(s) affected by the program or project. Enter in the format: 

two character state abbreviation-two character district number (e.g., CA-05 for California’s 

5th district, NC-10 for North Carolina’s 10th district). If all congressional districts in a state 

are affected, enter all for the district number, (e.g., MD-all for all congressional districts in 

Maryland). 

17. Proposed Project Start Date and 

End Date: 

(Required) 

17(a). Enter 1/1/2025 (this will be different for the NCC requests) as the proposed Start Date. 

17(b). The proposed End Date should be entered as 12/31/2025 or the end of the multi year 

grant period, if later (i.e., 12/31/2026 or 12/31/2027, as applicable). 

100 
LOW INCOME TAXPAYER CLINICS 101 

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V VI APPENDIX A GLOSSARY INDEX

Item Field Name Information 

18. Estimated Funding: (Required) 

18(a). Enter the amount of federal grant funds requested for 2025, regardless of whether the 

applicant is applying for a single year or multi year grant. As no more than $200,000 can be 

awarded, the amount should not exceed $200,000. 

18(b)–(e). Enter the amount of all matching funds by source. 

18(f). Enter any income the organization expects to generate from the program.
‚

Note: The total from lines (b)-(f) must equal or exceed the amount entered on line 18(a) to 

show that applicant can provide a dollar-for-dollar match. 

18(g). Enter the sum of the amounts in 18(a) through 18(f). The amounts contained here 

should also match the figures on Form 13424J, Detailed Budget Worksheet and Narrative 

Explanations. 

19. Is Application Subject to Review 

by State Under Executive Order 

12372 Process? 

(Required) 

Select “c. Program is not covered by E.O. 12372.” 

20. Is the Applicant Delinquent on 

any Federal Debt? 

(Required)

Select the appropriate box. This question applies to the applicant organization, not the 

person who signs as the authorized representative. Categories of federal debt include, 

but are not limited to: delinquent audit disallowances, loans, and taxes. If yes, include an 

explanation in an attachment. 
LOW INCOME TAXPAYER CLINICS

Item Field Name Information 

21. Assurances and Certifications 

and Authorized Representative: 

Check the box marked “I agree” after reviewing the Assurances and Certifications in 

Publication 3319. 

To be signed and dated by the authorized representative of the applicant organization. 

Enter the first and last name (Required), prefix, middle name; and suffix. Enter title, 

telephone number and, email (All required), and fax number. A copy of the governing body’s 

authorization for you to sign this application as the official representative must be on file in 

the applicant’s office. 

Note: Signing this form (Standard Form 424) certifies that the applicant will comply with 

the Assurances and Certifications listed in Publication 3319, Section, VI.D, National Policy 

Requirements and Administrative Requirements. Please carefully read the Assurances 

and Certifications before signing this form. When the application package is submitted the 

Standard Form 424 will be electronically signed. 

102 
LOW INCOME TAXPAYER CLINICS 103 

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VII I II III IV

V VI APPENDIX A GLOSSARY INDEX

INSTRUCTIONS FOR FORM 13424, LOW INCOME TAXPAYER CLINIC 

(LITC) APPLICATION INFORMATION 

This form is used to report basic information about the applicant, including the amount and period of the grant 

requested, contact information for the applicant’s sponsoring organization, the name and location of the clinic 

where services are provided, and key clinic staff members. The Program Office uses the information reported on 

this form to correspond with clinics and to publicize the location of clinics to taxpayers in IRS publications and 

online. Please follow the instructions carefully and report all information completely and accurately. A complete 

response means an entry must be provided for each field. 

All organizations submitting a Full Grant Application and NCC Request must complete this form. See 


Publication 3319, Section IV, Application and Submission Process.
 

Specific Instructions 

Grant Period Request 

Check the appropriate box to indicate whether a single year or multiyear grant is requested. Under IRC § 7526, 

the LITC Program Office is authorized to issue grants for a period of up to three years. Generally, applicants that 

have never been awarded an LITC grant are not eligible for a multiyear grant and may only request a single year 

grant. 

Enter the total amount, rounded to whole dollars, of funding requested for the grant year. The maximum funding 

that may be awarded is $200,000. 

NOTE: President Biden’s 2025 budget request includes a $200,000 per award funding cap, so the LITC Program 

Office is allowing applicants to request up to $200,000 for 2025. If Congress does not enact the increased funding 

cap, the Program Office will adjust each award accordingly to reflect any limitations in effect at that time. 

Applicant Information 

Enter the contact information for the organization applying for the grant. The name of the applicant must match 

exactly the name used to register on SAM.gov. If a grant is awarded, the award will be payable to the organization 

listed in this section. 

For Applicant’s Mailing Address, please provide a complete response, including zip plus-four code. Phone 

numbers should be formatted as 123-456-7890 x.111. 

Clinic Information 

This section is used to report information about the clinic where services are provided to taxpayers. If a grant is 

awarded, the information entered in this section will be used exactly as entered to prepare IRS Publication 4134, 

Low Income Taxpayer Clinic List. Publication 4134 is the primary tool for many low-income and ESL taxpayers 

to locate LITC services. Thus, the clinic name as provided should be the name used in materials publicizing 

the LITC’s services to taxpayers and the public. 

Please provide a complete response, including zip plus-four code, for the Clinic Street Address, and Clinic Mailing 

Address. Do not write “same.” Phone numbers should be formatted as 123-456-7890 x.111. When providing 

the clinic’s website address, please provide the direct link to the LITC page if one is available. If no website exists, 

write “none.” 
104 LOW INCOME TAXPAYER CLINICS

Please individually list all languages in addition to English in which services can be provided on site. If the clinic 

uses a telephone or internet based translation service, state “other languages through interpreter services.” 

All applicants must identify a Clinic Director, Qualified Tax Expert (QTE), and Qualified Business Administrator 

(QBA) responsible for clinic operations and management of funds. For more information on these positions, see 

Publication 3319, Section VI.C.i, Standards for Operating a Low Income Taxpayer Clinic. For the Clinic Director 

and QTE, list any applicable licenses and certifications. 

NOTE: During the application amendment process which takes place after grant recipients are selected, all clinics 

will be required to provide a statement certifying that the CD, QTE, and all qualified representatives working 

with the clinic are not under suspension or disbarment from practice before the IRS and are in good standing with 

all relevant professional state licensing authorities and federal courts. The Office of Professional Responsibility’s 

disciplinary look-up contains searchable information regarding censures of practitioners for Circular 230 

misconduct and suspensions and disbarments of individuals from practice before the IRS. See Search for 

Disciplined Tax Professionals | Internal Revenue Service (irs.gov). 

Tax Compliance Officer 

All applicants must identify a TCO. See Publication 3319, Section III.C.iii, Compliance with Federal Tax 

and Nontax Requirements and Glossary for a discussion of who may be designated to fill this role. The TCO 

is the individual responsible for handling the organization’s federal tax matters. Applicants must also provide 

documentation (e.g., articles of incorporation or a Form 2848, Power of Attorney and Declaration of 

Representative, signed by the appropriate official) that shows how the individual on Form 13424 is properly 

authorized to receive tax information to prevent the IRS from making an unauthorized disclosure. When 

providing articles of incorporation, ensure it is the most recent version. When providing Form 2848, be sure of 

the following: 

n	all required fields are completed; 

n	in section 3, the type(s) of tax are listed; (e.g., 940, 941, 1120, 1065, 990); 

n	in section 3, both current and past tax years are listed (e.g., 2024, 2023, 2022, 2021, 2020); 

n	in section 7, the form is signed by an officer of the corporation who is authorized under the articles of 


incorporation to designate an individual to receive federal tax information for the entity; and
 

n	in Part II, the form is signed by the person being authorized to receive the tax information. 

Complying with federal tax obligations is a requirement to receive an LITC grant, so it is imperative that the 

designated individual be knowledgeable and prepared to promptly address any federal tax issues of the applicant 

or the sponsoring organization. 

An applicant must be in full compliance with its federal tax responsibilities (filing and payment) when applying 

for an LITC grant and throughout the grant year. 
LOW INCOME TAXPAYER CLINICS 105 

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V VI APPENDIX A GLOSSARY INDEX

Form 13424 

(April 2018) 

Department of the Treasury - Internal Revenue Service 

Low Income Taxpayer Clinic (LITC) 

Application Information 

OMB Number 

1545-1648 

Grant Period Request (Check one) 

New application Single year Multi-year 

Non-Competitive continuation Second year Third year 

Grant amount requested (maximum $100,000) 

Applicant Information 

Legal name of sponsoring organization 

Prefix Last name First name Middle initial Suffix 

Title 

Phone number FAX number Email address 

Applicant's Mailing Address 

Street 

Street address line 2 

City State ZIP + 4 code 

Clinic Information 

Name of clinic 

Public telephone number Toll-Free telephone number (if applicable) FAX number 

Website address (if applicable) 

Languages served in addition to English 

Clinic Street Address Clinic Mailing Address 

Street Street 

City State ZIP + 4 code City State ZIP + 4 code 

Clinic Director Information 

Prefix Last name First name Middle initial Suffix 

Telephone number Email address 

Licenses/Certifications (Check all that apply) 

Attorney CPA Enrolled Agent Other 

Catalog Number 36126D www.irs.gov Form 13424 (Rev. 4-2018) 

Form 13424 
106 LOW INCOME TAXPAYER CLINICS

Page 2 

Qualified Tax Expert (QTE) 

Prefix Last name First name Middle initial Suffix 

Telephone number Email address 

Licenses/Certifications (Check all that apply) 

Attorney CPA Enrolled Agent Other 

Qualified Business Administrator (QBA) 

Prefix Last name First name Middle initial Suffix 

Telephone number Email address 

Tax Compliance Officer 

Prefix Last name First name Middle initial Suffix 

Title 

Telephone number Email address 

Instructions for Form 13424, Low Income Taxpayer Clinic (LITC) Application Information 

Purpose 

This form is used to report basic information about the applicant, including the amount and period of the grant requested, contact 

information for the applicant’s sponsoring organization, the name and location of the clinic where services are provided, and key clinic 

staff members. The Program Office uses the information reported on this form to correspond with clinics and to publicize the location of 

service providers to taxpayers in IRS publications and online. Please follow the instructions carefully and report all information 

completely and accurately. A complete response means an entry must be provided for each field. 

Who Must Complete This Form 

All organizations submitting a Full Grant Application or a Non-Competitive Continuation (NCC) Request must complete this form. See 

Publication 3319, Section IV, Application and Submission Process. 

Any forms submitted with a Full Grant Application or NCC Request may be released under the Freedom of Information Act (FOIA). In 

response to a FOIA request, the LITC Program Office will release these forms after appropriate redactions to ensure confidentiality of 

taxpayer information. 

Specific Instructions 

Grant Period Request 

Check the appropriate box to indicate whether a single or multi-year grant is requested. Under IRC § 7526, the LITC Program Office is 

authorized to issue grants for a period of up to three years. Applicants that have never been awarded an LITC grant are not eligible for 

a multi year grant and may only request a single year grant. 

Current grantees requesting a NCC Request must check the box indicating whether the request is for the second or third year of a 

multi year grant. 

Enter the total amount, rounded to whole dollars, of funding requested for the grant year. The maximum funding that may be awarded 

for any grant year is $100,000. 

Applicant Information 

Enter the contact information for the organization applying for the grant. The name of the applicant must match exactly the name used 

to register with the System for Award Management (SAM). If a grant is awarded, the award will be payable to the organization listed in 

this section. 

For Applicant’s Mailing Address, please provide a complete response, including zip plus-four code. Phone numbers should be 

formatted as 123-456-7890 x.111. 

Clinic Information 

This section is used to report information about the clinic where services are provided to taxpayers. If a grant is awarded, the 

information entered in this section will be used exactly as entered to prepare IRS Publication 4134, Low Income Taxpayer Clinic List. 

Publication 4134 is the primary tool for many low income and ESL taxpayers to locate LITC services. Thus, the clinic name entered 

should be the name used in materials publicizing the LITC’s services to taxpayers and the public. 

Catalog Number 36126D www.irs.gov Form 13424 (Rev. 4-2018) 
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Page 3 

Instructions for Form 13424, Low Income Taxpayer Clinic (LITC) Application Information (cont'd) 

Please provide a complete response, including zip plus-four code, for the Clinic Street Address, and Clinic Mailing Address. Do not write 

“same.” Phone numbers should be formatted as 123-456-7890 x.111. 

When providing the clinic’s website address, please provide the direct link to the LITC page if one is available. If no website exists, write 

“none.” 

Please individually list all languages in addition to English in which services can be provided on site. If the clinic uses a telephone or 

internet based translation service, state “other languages through interpreter services.” 

All applicants must identify a Clinic Director, Qualified Expert (QTE), and Qualified Business Administrator (QBA) responsible for clinic 

operations and management of funds. For more information on these positions, see Publication 3319, Section VI.C.i, Standards for 

Operating an LITC. For the clinic director and QTE, list any applicable licenses and certifications. 

NOTE: During the application amendment process, all clinics will be required to provide a statement certifying that the CD, QTE, and all 

qualified representatives working with the clinic are not under suspension or disbarment from practice before the IRS and are in good 

standing with all relevant professional state licensing authorities and federal courts. 

Tax Compliance Officer 

All applicants must identify a Tax Compliance Officer. See Section III.C.iii, Compliance with Federal Tax and Nontax Requirements and 

Glossary for a discussion of who may be designated. 

An applicant must be in full compliance with its federal tax responsibilities when applying for an LITC grant and throughout the grant 

year. 

Catalog Number 36126D www.irs.gov Form 13424 (Rev. 4-2018) 
108 LOW INCOME TAXPAYER CLINICS

INSTRUCTIONS FOR FORM 13424-J, DETAILED BUDGET WORKSHEET 

AND NARRATIVE EXPLANATIONS 

This form must be submitted with all Full Grant Applications and NCC Requests for an LITC grant. This form 

is used to provide a detailed explanation for each spending category in the proposed budget for the LITC grant, 

including how federal grant funds and matching funds will be spent during the grant period. All budgeted 

amounts must be reasonable, necessary, and allocable to this grant. In preparing the budget, adhere to existing 

guidelines in 2 CFR Part 200, 2 CFR Part 1000, and Publication 3319, which explain how budgeted amounts 

should be reported. See Publication 3319, 2 CFR § 200.306, and 2 CFR § 1000.306 for guidance on matching 

funds. 

NOTE: 

n	Each budget item does not require a dollar-for-dollar match, but the total matching funds must equal or 

exceed the total federal funds requested. For more information on meeting the matching funds requirement, 

See Publication 3319, Section IV.E.iii, Meeting the Matching Funds Requirement. 

n	Federal funds are those funds the applicant is seeking from the IRS in support of the LITC Program. 

n	Non-federal funds are funds from other sources that the applicant has or will have available to spend on the 

LITC Program. These are considered matching funds. 

n	2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards (Uniform Guidance) provides guidance about allowable and unallowable expenses. Also, see 

Publication 3319, Section IV.E.iii, Meeting the Matching Funds Requirement, for a list of common allowable 

and unallowable expenses. 

n	Please round figures to whole dollars. 

n	Budgets should only include funding requested for grant year 2025, even if an applicant is applying for a 

multiyear grant. 

All organizations submitting a Full Grant Application or NCC Request must complete this form. Failure to 

provide this information will result in non-consideration of the Full Grant Application or NCC Request. 

Each lettered section of the Budget Narrative corresponds to an expense category in the Detailed Budget 

Worksheet. The information provided in the narrative should be sufficiently detailed so that a reviewer can arrive 

at the same amounts listed on the Budget by expense and by category (federal or match). 

A. Personnel 

Report salaries and wages that will be paid to LITC staff. Do not include fringe benefits in this category (fringe 

benefits should be accounted for in category B). In the explanation, list each staff member’s name or if they are 

“to be hired,” position, rate of pay and time to be devoted to clinic activities (hourly wage and number of hours 

of service, or annual salary and percentage of annual salary). State the portion of each staff member’s budgeted 

salary or wages to be paid from federal and matching funds, as well as the source of the matching funds. Volunteer 

in-kind services should not be included under the Personnel category. They should be included under category H, 

Other Expenses. 

1. Calculate the Full Time Equivalent for each clinic employee. 

Determine each clinic staff member’s full-time equivalent (FTE). The FTE number is arrived at by 

dividing the number of hours the employee will devote to LITC activities during the year by the total 
LOW INCOME TAXPAYER CLINICS 109 

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hours that will be worked by a full-time employee in a year. For many organizations, an employee is 

considered full-time if he or she works 40 hours a week (for other programs it might be a different 

number). For this example, we will assume full-time is 40 hours per week. In one year, a full-time 

employee would work 40 hours multiplied by 52 weeks for a total of 2,080 hours. If the employee will 

devote 2,080 hours to the LITC, his or her FTE will be 1.0 (2,080 LITC hours/2,080 total hours). 

If the employee will work 1,560 hours on LITC activities, then the FTE will be .75 (1,560 LITC 

hours/2,080 total hours). 

Annual leave, sick leave, compensatory time off, and other approved leave categories are considered 

“hours worked” for purposes of defining full-time equivalent employment that is reported. 

2. Calculate the personnel expense for each staff member. 

For full-time salaried employees, multiply the total salary by the FTE, as calculated above, to arrive at 

the LITC share of the personnel expense. 

For salaried part-time staff, calculate the percentage of the staff ’s time to be devoted to the LITC 

(LITC hours/total hours) and then multiply that percentage by the employee’s total salary. 

For hourly employees, multiply the LITC hours to be worked by the hourly rate. 

3. Determine and list out the dollar amount attributable to federal and match. 

The FTE percentage represents the maximum portion of the employee’s wages that can be allocated to 

the LITC grant, using grant funds (federal funds), matching funds, or a combination of both. 

4. List sources of match. 

B. Fringe Benefits 

Report fringe benefits that will be paid on behalf of LITC staff whose wages and salaries are reported in 

category A, Personnel. Include in the explanation: 

n	The fringe benefits rate(s), including the formula (methodology) for calculating fringe benefits for each 

position listed in category A; 

n	The items that are included in fringe benefits; 

n	The dollar amount attributable to federal and match; and 

n	Source of matching funds. 

C. Travel 

This expense category is used to report budgeted travel costs, including costs associated with attendance at the 

Annual LITC Grantee Conference and other travel expenses directly related to conducting LITC business or 

activities. In the explanation, identify: 

n	The travel costs to be incurred; 

n	Whether the costs will be paid with federal or matching funds; and 

n	The source of the matching funds. 

If using a mileage rate, show the computation. 
110 LOW INCOME TAXPAYER CLINICS

D. Equipment 

This expense category is used to report the budgeted cost of equipment purchases that equal or exceed $10,000 

that will be used in operating an LITC program. See 2 CFR § 200.1. Equipment costing less is included in 

category E, Supplies. Report leased equipment under category F, Contractual, and equipment maintenance expense 

under category H, Other Expenses. 

Donated equipment may be included in the matching funds column and must be valued at the fair market value 

of the property at the time of the donation. In the explanation, identify: 

n	The equipment that will be purchased or donated; 

n	Whether the associated costs will be paid using federal or matching funds; and 

n	The source of the matching funds. 

If there will be third-party in-kind contributions of equipment, identify: 

n	The equipment; 

n	The donor; and 

n	How the valuation was determined. 

E. Supplies 

This expense category is used to report the cost of supplies and equipment costing less than $10,000 that will be 

used in operating the LITC. Donated supplies may be included in the matching funds column and are valued at 

the fair market value of the property at the time of the donation. In the explanation, identify: 

n	The supplies to be used; 

n	Whether the associated costs will be paid using federal or matching funds; and 

n	The source of the matching funds. 

If there are third-party in-kind contributions of supplies, identify: 

n	The supplies; 

n	The donor; and 

n	How the valuation was determined. 

F. Contractual 

This expense category is used to report the budgeted cost of rent, utilities, and other contracted items or services 

that will be used in operating an LITC program. Donated space may be included as matching funds and the value 

assigned may not exceed the fair market rental value of comparable space. The explanation should identify: 

n	The nature of the expense; 

n	Whether the associated costs will be paid using federal or matching funds; and 

n	The source of the matching funds. 

If a contracted item or service pertains to other programs in addition to LITC activities, only the portion 

directly attributable to LITC activities may be allocated to the LITC program. The narrative must explain the 

methodology used to apportion costs between the LITC activities and other programs. 
LOW INCOME TAXPAYER CLINICS 111 

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Necessary and reasonable expenses that support LITC activities as well as functions of the organization should 

be allocated and charged as a direct cost of award funds if it is practical to separate the portion of the expense 

allocable to LITC activities. The determination of whether it is practical or reasonable to allocate expenses directly 

in proportion to use depends on several factors, including the size of the organization running the LITC, size and 

number of other functions the organization operates, and the amount of the expense. 

G. Construction 

This category is not applicable to this grant. No expenses are allowed. 

H. Other Expenses 

This expense category is used to report all other direct costs that will be incurred in operating the LITC program 

that are not properly included in categories A through G. The value of volunteer in-kind services is included in 

this category as matching funds. The explanation should identify: 

n	The type of expense; 

n	Whether the cost will be paid using federal or matching funds; and 

n	The source of the matching funds. 

The explanation must also disclose the rate or rates that will be used to value volunteer in-kind services and the 

number of volunteer hours that will be provided, categorized by the type of service or volunteer, as appropriate. 

See Publication 3319, Section IV.E.iii, Meeting the Matching Funds Requirement, Determining the Value of Volunteer 

Services. 

I. Total Direct Charges 

The total of the direct charges is the sum of lines A–H for each column. 

J. Indirect Charges 

Report indirect costs not directly related to the LITC program but incurred as part of the general overhead and 

administration of the sponsoring organization. Necessary and reasonable expenses that support LITC activities 

as well as functions of the organization should be allocated and charged as a direct cost of award funds if it is 

practical to separate the portion of the expense allocable to LITC activities. The determination of whether it is 

practical or reasonable to allocate expenses directly in proportion to use depends on several factors, including the 

size of the organization operating the LITC, size and number of other functions the organization operates, and the 

amount of the expense. The Uniform Guidance defines indirect costs as: 

[T]hose costs incurred for a common or joint purpose benefitting more than one cost objective, and 

not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to 

the results achieved. (2 CFR § 200.1.) 

For example, an organization has a $5,000 expense that supports LITC activities and two other programs the 

organization operates. Suppose the organization can spend an additional $100 in administrative costs to accurately 

allocate the $5,000 among the three programs in proportion to the benefit each received. In that case, the 

allocation is reasonable and the organization should perform the allocation and charge the portion of the $5,000 

that is allocable to LITC activities as a direct cost. 
112 LOW INCOME TAXPAYER CLINICS

Now suppose the organization has a $5,000 expense that supports LITC activities and two other programs the 

organization operates, but to properly allocate the $5,000 among the three programs in proportion to the benefit 

each received, it would cost the organization an additional $2,000 in administrative costs. In that case, direct 

allocation of the cost is not cost-effective, and the organization can choose to account for the $5,000 expense as 

an indirect cost. The organization then apportions the total indirect costs (i.e., the indirect cost pool) to each of 

the benefiting programs using a method that is consistent, reasonable, auditable, and in accordance with generally 

accepted business practices. 

The Uniform Guidance in section 200.414(b) recognizes that because of the diverse characteristics and accounting 

practices of nonprofit organizations, it is not possible to specify the types of cost that may be classified as indirect 

costs in all situations. The purpose of the federal award is the determining factor in distinguishing direct from 

indirect costs, rather than the nature of the goods and services expensed. 

Typical indirect expenses may include: 

n	Salaries and wages of administrative and support staff; 

n	Related employee benefits; 

n	Facility occupancy costs (e.g., utilities, security, maintenance); 

n	Office supplies; and 

n	Legal and auditing charges. 

Once the organization has classified expenses as either direct or indirect, the organization must determine how 

to allocate the indirect costs amongst the programs that they benefit, so that LITC funds do not subsidize the 

indirect costs of other programs or functions of the organization. To calculate the amount of federal funds 

allocable to indirect costs, the organization may use a negotiated indirect cost rate agreement (ICRA) approved by 

the organization’s cognizant agency. If the organization has never obtained a negotiated indirect cost rate or if its 

ICRA has expired, it may elect to apply the de minimis rate of 15 percent. Note that once elected, the 15 percent 

rate must be used consistently for all federal awards until the organization chooses to negotiate for a rate. 

Matching Funds 

Complete this section by providing a narrative that includes: 

n	A list of all sources of matching funds; 

n	The amount of matching funds broken down by source; and 

n	The methodology used for any calculations. 

The clinic must state explicitly that matching funds to be provided to the LITC program: 

n	Will not be used as matching funds for any other federal program; and 

n	Will not be funds received from any other federal grant unless specifically authorized by statute to be eligible 

as matching funds. 

An employee of the grant recipient may not be treated as a volunteer for purposes of valuing in-kind services. 

For example, suppose an LITC pays an employee an hourly wage to work at the LITC three days a week, and the 

employee chooses to spend an additional two days each week volunteering at the LITC. In the example, the LITC 

may charge the employee’s wages as an expenditure of federal or matching funds, but it cannot apply the value of 

the two days spent volunteering as a contribution to help meet the matching fund requirement. 
LOW INCOME TAXPAYER CLINICS 113 

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FULL-TIME EQUIVALENT CALCULATION 

This is a further demonstration of determining FTE and also determining what is properly counted as matching 

funds for purposes of the LITC grant. 

Example FTE Calculations 

ABC Legal Services LITC computes a 1.0 FTE based on a 40-hour work week (2,080 hours per year). 

Example: Clinic Director/(QTE) – John Fordham, Esq. 

John works full-time at ABC Legal Services. He will spend 32 hours per week on LITC grant 

activities, for an annual total of 1,664 hours, making John a 0.80 FTE (1,664/2,080) for purposes of 

the LITC grant. John’s annual salary is $89,000. Since John’s time spent on LITC grant activities is 

equivalent to 0.80 FTE, he will receive $71,200 of his total salary ($89,000) for his work in the LITC. 

This is calculated by multiplying his FTE annual salary of $89,000 by 0.80 for a total of $71,200 

($89,000 x 0.80 = $71,200). John’s compensation is comprised of $70,000 of grant funds and $29,000 

operating funds. From the $71,200 in compensation for work on LITC activities, $50,000 will be paid 

from LITC grant funds (federal funds), and $21,200 from operating funds. Thus, a maximum of $21,200 

may be classified as matching funds. 

Example: Paralegal – Alice Gonzaga 

Alice works part-time for ABC Legal Services, for a total of 1,040 hours. Annually she will spend a total 

of 900 hours on LITC grant activities, making Alice a 0.43 FTE (900/2,080) for purposes of the LITC 

grant. Alice is paid $22 per hour. She receives total annual compensation of $22,880 (1,040 x $22); 

$19,800 (900 x $22) of which will be compensation for her work in the LITC. Alice’s compensation will 

be comprised of $10,000 paid from LITC grant funds (federal funds), and $9,800 (matching funds) paid 

from XYZ Private Foundation funds. The remaining compensation of $3,000 is for non-LITC work and 

therefore is not eligible match. 

Example: Intake – Ruth Washington 

Ruth works full-time at ABC Legal Services. She will spend 18.4 hours per week on LITC grant activities, 

for an annual total of 957 hours, making Ruth a 0.46 FTE (957/2,080) for purposes of the LITC grant. 

Ruth is paid $15 per hour. She receives total annual compensation of $31,200 (2,080 x $15). Ruth’s 

compensation will be comprised of $14,355 paid from LITC grant funds (federal funds), and $16,845 for 

non-LITC work is paid from operating funds. None of Ruth’s compensation may be classified as matching 

funds, because all of her time spent on LITC grant activities is compensated using LITC grant funds. 

Example: Receptionist – Debra Chapman 

Debra works full-time at ABC Legal Services. She provides administrative and clerical support to three 

programs including the LITC program. Debra will spend one-third of her time on LITC activities, 

making her a one-third FTE for purposes of the LITC grant. Debra’s annual salary is $30,000, so $10,000 

(1/3 x $30,000) of her annual salary is allocable to LITC activities. The $10,000 allocable portion 

will be paid using $6,000 from LITC grant funds (federal funds), and $4,000 paid from private cash 

contributions. Thus, a maximum of $4,000 may be classified as matching funds. 
114 LOW INCOME TAXPAYER CLINICS

Form 13424-J

(May 2018) Detailed Budget Worksheet 

Department of the Treasury - Internal Revenue Service OMB Number 

1545-1648 

Name of Low Income Taxpayer Clinic Grant Period 

From To

Expense Categories Federal Match Total

A. Personnel 

B. Fringe Benefits 

C. Travel 

D. Equipment 

E. Supplies 

F. Contractual 

G. Construction 

H. Other Expenses 

I. Total Direct Charges 

J. Indirect Charges 

K. Totals 

Catalog Number 57758V www.irs.gov Form 13424-J (Rev. 5-2018) 

Form 13424-J 
LOW INCOME TAXPAYER CLINICS 115 

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Page 2 

Detailed Budget Narrative Explanations
­

A. Personnel 

B. Fringe Benefits 

C. Travel 

D. Equipment 

E. Supplies 

F. Contractual 

Catalog Number 57758V www.irs.gov Form 13424-J (Rev. 5-2018) 
116 LOW INCOME TAXPAYER CLINICS

Page 3 

G. Construction 

H. Other Expenses 

I. Total Direct Charges 

J. Indirect Costs 

Matching Funds 

Catalog Number 57758V www.irs.gov Form 13424-J (Rev. 5-2018) 
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FORM 13424-M, LOW INCOME TAXPAYER CLINIC (LITC) APPLICATION 

NARRATIVE 

This form is used to report background information about the applicant, details about the Program Performance 

Plan, and information for a Civil Rights Review. The Program Office uses the information reported on this 

form to determine applicant eligibility. The information collected with this form will be closely evaluated when 

reviewing and scoring the grant application. Please answer all the questions carefully and report all information 

completely and accurately. A complete response means an entry must be provided for each field. 

When completing Form 13424-M, LITC Application Narrative, refer to the new guidance document at 

www.taxpayeradvocate.irs.gov/about-us/litc-grants/. All organizations submitting a Full Grant Application must 

complete this form. 
118 LOW INCOME TAXPAYER CLINICS

Form 13424-M 

(March 2019) 

Department of the Treasury - Internal Revenue Service 

Low Income Taxpayer Clinic (LITC) 

Application Narrative 

OMB Number 

1545-1648 

Applicant Organization name 

Use this template to complete the Background Information, Program Performance Plan, and Civil Rights Review required to be submitted with all LITC 

grant applications. Your responses may contain internal references. There is no need to reprint text contained elsewhere on this form. 

Background Information 

This section is designed to solicit information concerning an applicant’s qualifications.The information will be used to determine whether the organization 

has sufficient experience in delivering services to low income and ESL individuals and the infrastructure to properly manage federal funds. Provide 

specific responses for each of the following requirements and keep comments concise and relevant. 

I. Experience 

A. Describe the applicant’s experience in operating an LITC program. Do not include information about the experience of specific individuals here. If the 

applicant has no experience operating an LITC program, describe the applicant's experience in delivering services (e.g., representation, education, 

and advocacy) to low income and ESL individuals and families. Include types of services provided, languages served, and number of individuals 

reached 

B. List the applicant’s existing affiliations with organizations, such as schools, governmental bodies, or other charitable organizations 

C. Describe the applicant’s experience supervising staff, students, and volunteers and provide examples of how supervision is provided 

D. Describe the applicant’s experience networking with their affiliates and other community-based organizations with which it can work to reach 

taxpayers and experience providing technical assistance to other organizations 

II. Financial Responsibility 

A. Describe the applicant’s ability to properly spend and account for program funds. Include examples of experience in managing federal grants, if any, 

and a description of the organization's existing accounting system and accounting support staff. The program office may request copies of the internal 

accounting procedures as needed 

1. Describe accounting procedures and accounting support staff 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 

For Paperwork Reduction Act Notice, see Pub 3319. 
LOW INCOME TAXPAYER CLINICS 119 

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Page 2 of 6 

2. Describe the method for tracking and verifying expenditures to ensure that LITC grant funds and matching funds will be used solely for qualifying LITC 

activities 

i. Does the applicant operate a VITA Site Yes No 

ii. If yes, specifically identify how the applicant will ensure LITC funds are not utilized for VITA activities 

3. Describe the plans for audits and controls 

4. With regard to the financial statements submitted with this application or those uploaded to Single Audit Warehouse, provide the following information: 

(if a profit and loss statement or other substitute was submitted because financial statements were not available, skip to question 5) 

Unaudited Audited 

i. If audited, was the audit a single audit conducted in accordance with 2 CFR 200.501 Yes No 

ii. If audit was conducted in accordance with 2 CFR 200.501, was the audit report uploaded to the clearinghouse Yes No 

iii. Indicate whether the auditor provided an: 

Unmodified opinion Qualified opinion Adverse opinion Disclaimer opinion 

iv. If you answered anything other than unmodified, provide an explanation as to the reason for the type of opinion provided 

v. Indicate the year-end date of the financial statements submitted (MM/DD/YYYY) 

5. Provide the name and describe the qualifications and relevant expertise of the Qualified Business Administrator (QBA) (the person with business 

administration and federal grants management experience) 

Program Performance Plan 

This section of the application is designed to solicit information concerning the ability of an applicant to operate a quality LITC. Provide specific 

responses for each of the following requirements and keep comments concise and relevant. 

I. Program Staff 

A. For 1.-2., provide the staff member's name and list the qualifications and expertise of the individual as it relates to the position 

1. The Qualified Tax Expert (QTE) 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 
120 LOW INCOME TAXPAYER CLINICS

Page 3 of 6 

2. The Clinic Director 

B. List the titles, responsibilities, and qualifications of clinic staff other than the Clinic Director, QTE, or QBA 

C. If students will be used by the clinic to provide representation, education or advocacy, indicate the number of students per semester and type (law 

students, graduate accounting students, etc.) 

1. If using students, will the clinic obtain a special appearance authorizing students to represent taxpayers before the IRS; and Yes No 

2. Will permission be obtained from the United States Tax Court for students to practice before the Court Yes No 

D. Identify clinic staff authorized to represent taxpayers before the IRS and identify whether each is an attorney, Certified Public Accountant, or Enrolled 

Agent 

E. Identify clinic staff admitted to practice before the U.S. Tax Court and include each individual's Tax Court bar number 

F. Explain the method used to track staff time, student time, and how the type of activity is tracked and coded 

II. Taxpayer Services 

A. Describe the proposed program plan for the period for which the grant is requested (Form 424, section 17) 

1. Identify the geographic area(s) the clinic will serve. Describe the identified population for low income and ESL representation, education, and 

advocacy. Provide demographic information including the total population, number of low income residents, and number of ESL residents, information 

about languages present, and the source of the data supplied 

2. Describe the type of representation services to be provided 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 
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Page 4 of 6 

i. Describe the method used to track the 90/250 income requirement. Include an explanation of any alternative methods used to measure income for 

purposes of determining eligibility for controversy services (e.g., seasonal workers) 

ii. Describe the method used to track the amount in controversy for any taxable year and state the policy that will be used to accept cases when the 

amount in controversy exceeds the amount specified in IRC § 7463 (currently $50,000) 

iii. Briefly describe the procedures for intake, assignment, and monitoring of representation cases 

B. Describe the consultation services to be provided and how they will be made available to taxpayers 

C. Describe the educational activities to be provided, including educational topics to be covered, how these topics were identified, and how they will be 

made available to taxpayers. Include details about the review process for educational materials to ensure such materials are accurate 

III. Clinic Operations 

A. Describe plans for tracking the delivery of services to low income and ESL taxpayers and how that data will be used to assess and shape future 

service delivery 

B. Describe plans to protect taxpayer privacy and to maintain confidentiality of taxpayer information and any tax return information. Describe the 

procedures used to safeguard client records. Is there a private office or conference room to meet with clients 

C. Describe the clinic’s publicity plan, including different methods, types of media, and potential venues for outreach to low income taxpayers and ESL 

taxpayers 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 
122 LOW INCOME TAXPAYER CLINICS

Page 5 of 6 

D. Indicate the dates, days, and hours of clinic operation. State whether the clinic will be open full-time and year-round. Describe plans for staffing the 

clinic during periods of student absences if the LITC is part of an academic institution. Specifically state whether the clinic will accept and work new 

cases during periods of student absences or merely refer taxpayers to other organizations 

E. Describe the clinic’s plans for charging nominal fees, if any, and the amount 

IV. Volunteers 

A. Describe the applicant’s pro bono panel and how panel members will be identified and recruited. If the applicant is using a local, state, or national pro 

bono panel, explain the referral process 

B. Describe the procedures used to assign cases to volunteers, monitor case progress, and evaluate services to ensure that taxpayers receive quality 

assistance 

C. Detail the method used to track volunteer time 

V. Training and Resources 

A. Describe the in house training to be provided to clinic staff, students, and volunteers including a description of the training topics, and the 

qualifications of trainer(s) and person(s) creating the materials 

B. Identify the continuing professional education (CPE) activities the clinic staff and volunteers anticipate attending 

C. Describe the clinic’s tax library and any plans to provide access to other research resources 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 
LOW INCOME TAXPAYER CLINICS 123 

APPENDIX A

VII I II III IV

V VI APPENDIX A GLOSSARY INDEX

Page 6 of 6 

VI. Program Monitoring, Evaluation, and Reporting 

A. Describe the strategy for monitoring and evaluating program results (in short and long-term), including how success will be defined and measured 

B. Indicate how the clinic intends to measure and address client satisfaction 

VII. Program Numerical Goals 

If requesting a multi-year grant, state goals for each year. Project numerical goals for First Year Second Year 

(if applicable) 

Third Year 

(if applicable) 

A. New representation cases opened in the calendar year (do not include beginning 

inventory); 

B. Consultations with low income and ESL taxpayers; 

C. Educational activities to low income and ESL taxpayers; and 

D. Low Income and ESL taxpayers to be reached in educational activities 

Civil Rights Review 

This information is mandatory and required of every applicant annually. Responses to the civil rights questions should be directly related to the part of 

the sponsoring organization that receives funding or where the LITC will be housed. For example, if the law school or business school within a university 

applies for funding for the LITC Program, the responses to the civil rights questions should only be in reference to the part of the university where the 

LITC will be housed, not the entire university. If the applicant does not have any information to report on these questions, a negative response is 

required such as none. If additional space is needed attach additional pages. Not applicable or NA is not an acceptable response. The applicant must 

provide the following information as a condition of eligibility under the LITC Program. 

A. A list of active lawsuits or complaints naming the applicant which allege discrimination on the basis of race, color, national origin, age, sex, or 

disability with respect to service or benefits being provided. The list should include the date the lawsuit or complaint was filed; a summary of the 

allegation; and the status of the lawsuit or complaint, including whether the parties to a lawsuit have entered into a consent decree 

B. A description of all pending applications for financial assistance and all financial assistance currently provided by other federal agencies 

C. A summary of all civil rights compliance review activities conducted in the last three years. The summary shall include the purpose or reason for the 

review; a summary of the findings and recommendations of the review; and a report on the status or disposition of such findings and 

recommendations 

D. A description of how the needs of individuals with limited English proficiency (LEP) or individuals who may need a reasonable accommodation will be 

addressed in order to access services 

E. Does the applicant agree to compile and maintain all required records, as appropriate, according to the agency's guidelines Yes No 

F. Does the applicant agree to display Publication 4053, IRS Civil Rights Poster Yes No 

Catalog Number 59958R www.irs.gov Form 13424-M (Rev. 3-2019) 
124 LOW INCOME TAXPAYER CLINICS

COMPLETING THE PROJECT ABSTRACT IN GRANT SOLUTIONS 

The Project Abstract allows grant recipients that have been awarded a multiyear grant to update information 

reported on the original Form 13424-M, Low Income Taxpayer Clinic (LITC) Application Narrative. The Project 

Abstract is required in years two and three of multiyear grants and is used to report numerical goals, material 

changes to the program plan, the civil rights review responses, and a statement about the availability of the 

applicant’s audit on the Federal Audit Clearinghouse (FAC), if necessary. 

Only grant recipients submitting an NCC Request must complete and submit a Project Abstract during the 

application process. The Project Abstract must contain the following information regarding the grant year for 

which the NCC Request is being submitted. 

The Project Abstract starts as a completely blank document. The grant recipient must provide responses to Items I, 

II, and III, including each subpart, and IV. There is no need to reprint the full text below in the Project Abstract. 

I. Numerical Goals 

List separately numerical goals for each of the following: 

i.	 New representation cases opened during the reporting period (see Form 13424-K, line 1B); 

ii. Consultations (see Form 13424-A, line 6C); 

iii. Educational activities to be conducted to low-income and ESL taxpayers (see Form 13424-A, sum of lines 

2A and 2B); and 

iv.	 Low-income and ESL taxpayers to be reached in educational activities (see Form 13424-A, sum of lines 3A 

and 3B). 

II. Changes to the Program Plan 

Enter a description of any material changes to the description of the Program Plan reported on the Form 

13424-M, Low Income Taxpayer Clinic (LITC) Application Narrative, submitted with your original multiyear 

grant application. If no changes are anticipated, please indicate “no changes” in the space provided. 

III. Civil Rights Review Responses 

This information is mandatory and required of every applicant annually. Responses to the civil rights questions 

should be directly related to the part of the sponsoring organization that receives funding or where the LITC will 

be housed. For example, if the law school or business school within a university applies for funding for the LITC 

Program, the responses to the civil rights questions should only be in reference to the part of the university where 

the LITC will be housed, not the entire university. If the applicant does not have any information to report on 

these questions, a negative response is required such as “none”. If additional space is needed attach additional 

pages. “Not applicable” or “N/A” is not an acceptable response. The applicant must provide the following 

information as a condition of eligibility under the LITC Program: 

i.	 A list of active lawsuits or complaints naming the applicant that allege discrimination on the basis of race, 

color, national origin, age, sex, or disability with respect to service or benefits being provided. The list 

should include the date the lawsuit or complaint was filed; a summary of the allegation; and the status of 

the lawsuit or complaint, including whether the parties to a lawsuit have entered into a consent decree. 

ii. A description of all pending applications for financial assistance and all financial assistance currently 

provided by other federal agencies. 
LOW INCOME TAXPAYER CLINICS 125 

APPENDIX A

VII I II III IV

V VI APPENDIX A GLOSSARY INDEX

iii. A summary of all civil rights compliance review activities conducted in the last three years. The summary 

shall include the purpose or reason for the review; a summary of the findings and recommendations of the 

review; and a report on the status or disposition of such findings and recommendations. 

iv.	 A description of how the needs of individuals with limited English proficiency (LEP) and individuals who 

may need a reasonable accommodation will be addressed in order to access services. 

v.	 Does the applicant agree to compile and maintain all required records, as appropriate, according to agency 

guidelines? 

vi. Does the applicant agree to display Publication 4053, IRS Civil Rights Poster? 

IV. Statement About Availability of Audit on the Federal Audit Clearinghouse 

If applicable, provide a statement about the availability of the sponsoring organization’s audit on the FAC. 

Example Project Abstract: 

I. Projected Numerical Goals for 2025: 

i.	 200 new representation cases; 

ii. 40 consultations; 

iii. 10 educational activities to be conducted to low-income and ESL taxpayers; and 

iv.	 200 low-income and ESL taxpayers to be reached in educational activities. 

II. Changes to the Program Plan 

Beginning on January 5, XXXX, Saturday operating hours will be extended from 9am–1pm to 9am–2pm. As of 

February XXXX, Jane Doe will be designated as QBA. Ms. Doe holds a Master’s degree in accounting from the 

University of Columbia and has 10 years of experience managing federal grants. 

III. Civil Rights Review Responses 

i.	 Active lawsuits or complaints naming the applicant that allege discrimination on the basis of race, color, 

national origin, age, sex, or disability with respect to service or benefits being provided: None. 

ii. Pending applications for financial assistance: Legal Services Corporation, Basic Field Grant $100,000. 

Financial assistance currently provided by other federal agencies: State Legal Services, Operations Grant: 

$200,000. 

iii. Equality and Inclusion Committee (Committee) annually reviews the policies governing employee 

supervision and how services are delivered to clients for compliance with civil rights protections. The 

Committee issues a written report with recommendations to the Board of Directors. The Committee’s 

most recent report indicated that the racial and ethnic diversity of the LITC’s staff fairly represents the local 

population the LITC serves. 

iv.	 The applicant has bi-lingual staff members who speak English and Spanish and other staff members who 

speak English and French. The clinic uses telephone interpretation for other languages and a translation 

service for required documents and correspondence in other languages. The clinic notifies applicants of the 

right to reasonable accommodations on the reverse of its investigative retainer and client retainer. 
126 LOW INCOME TAXPAYER CLINICS

v. Yes 

vi. Yes 

IV. Statement about availability of audit on the Federal Audit Clearinghouse 

The applicant’s single audit for fiscal year XXXX is available on the FAC. 
LOW INCOME TAXPAYER CLINICS 127 

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

APPENDIX B 

FORMS FOR REPORTING LITC GRANTEE ACTIVITIES 
128 LOW INCOME TAXPAYER CLINICS

 

REPORTING FORMS1 

All reports are to be submitted through GrantSolutions. The forms contained in this Appendix are provided for 

reference purposes only. 

Due dates for reporting forms are:
 

Interim report: July 31, 2025
 

Year-end report: March 31, 2026
 

Timely submission of reporting forms is one criterion for evaluating clinic performance. If a grant recipient 

anticipates needing additional time to submit a report, the Clinic Director should address the situation with the 

assigned advocacy analyst as far in advance of the due date as possible. 

Content of the reports are subject to and may be released under the Freedom of Information Act (FOIA). For 

this reason, it is important that when reporting client success stories or emerging issues clinics are careful to 

ensure that the taxpayer cannot be identified by the details supplied in the report. In response to a FOIA request, 

the LITC Program Office will release these forms after having ensured that the clinic has properly redacted 

information in order to protect the confidentiality of taxpayer information. 

In addition to the instructions provided in this appendix, the Program Office routinely provides report training 

to help ensure that clinic reports are complete and accurate. Training is announced through the LITC Toolkit and 

usually takes place several weeks in advance of the report due date. Additional instructions about reporting for 

ESL Education Pilot Program recipients is provided below. 

Specific questions about how to report an item or activity of the clinic can be raised to the Advocacy Analyst 

assigned to the clinic. For questions or problems working within GrantSolutions, contact Michael Condict at 

michael.j.condict@irs.gov. 

LITC GRANT RECIPIENT REPORTING REQUIREMENTS* 

Clinics are required to submit the following forms twice per grant year, as an Interim and a Year-end Report, 

unless otherwise noted: 

q	Standard Form 425, Federal Financial Report (Year-end only); 

q	Form 13424-A, Low Income Taxpayer Clinic (LITC) General Information Report; 

q	Form 13424-B, Low Income Taxpayer Clinic (LITC) Case Issues Report (Year-end only); 

q	Form 13424-C, Low Income Taxpayer Clinic (LITC) Advocacy Information Report (Year-end only); 

q	Form 13424-K, Low Income Taxpayer Clinic (LITC) Case Information Report; 

q	Form 13424-L, Statement of Grant Expenditures and Narrative Explanations; and 

q	Form 13424-N, Low Income Taxpayer Clinic (LITC) Program Narrative Report. 

* If you operated an ESL Education Pilot Program only, you are required to submit the following at interim 

and year-end: Standard Form 425, Form 13424-A (excluding sections 6-10), Form 13424-C, Form 13424-L, 

and Form 13424-N (excluding section 2.v- 2.vii). If the clinic provided any consultations or casework assistance 

during the reporting period, then all forms need to be completed in their entirety. 

1 Where form instructions differ from guidance found in this publication, please follow the Publication 3319 guidance. 
LOW INCOME TAXPAYER CLINICS 129 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Reporting Period 

Clinics are required to report on LITC activities twice for each grant year. The grant year is January 1 through 

December 31 for the year for which the grant was awarded. An Interim Report is required to report activities 

conducted for the period from January 1 through June 30. A Year-end Report is required to report activities 

conducted for the entire grant year, with one exception. For the year-end Form 13424-N, sections 3 & 4, report 

emerging issues and success stories from the second half of the year only. Check the appropriate box at the 

beginning of the form indicating for which period the report is being completed. 

Accessing Reporting Forms on GrantSolutions 

First, login to GrantSolutions and navigate to the My Grants List screen. Grant Project Cards will appear on 

the screen, each representing an individual Grant Project. Grant Project information appears on each card and 

includes the Grant Number, FAIN, Grant Project Status, Project Title, and Grant Program. 

As a user, you can change how you view the information on the screen. The view options are either grid view or 

list view. 
130 LOW INCOME TAXPAYER CLINICS

The grid view is shown below and can be accessed by clicking on the grid icon. 

The list view is shown below and can be accessed by clicking on the list icon. 
LOW INCOME TAXPAYER CLINICS 131 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

The progress reporting forms are not available in the new 

experience view, and you will need to change the view to classic. 

To change to the classic, do the following: 

Click on the Avatar next to your initials. It will expand to a list 

of options. Click on Switch Back to Classic. It is important 

to note that the system resets back to the new experience after 

every logout. 

Next, a survey pop up box will appear. You can either choose to start a survey or select No Thanks. After you 

complete the survey or select No Thanks, the system will navigate to the screen below. The system should take 

you to the active grants. Verify the budget period is correct and click on the Progress Reporting link. If the grant 

period you are searching for is not showing on the screen, click on show expired grants. 

The system will then navigate to the screen below and follow these instructions: 

n	Select which form you wish to view from the drop-down list (except Standard Form 425, which is found 

elsewhere within GrantSolutions; see next section of this appendix). Click the drop-down arrow by the 

Report Name field and select the specific form.
 

n	The Funding/Grant Period must be selected by clicking on the drop-down arrow for that field.
 

n	To initiate/open a form for the first time, click on the Plus Sign icon.
 

n	To edit a form, click on the Pad/Pencil icon.
 

n	To view the status of a report form and make edits, click on the Graph icon.
 

n	To print a form, click on the Printer icon.
 

n	To view and print a form, click on the Eye icon.
 
132 LOW INCOME TAXPAYER CLINICS

NOTE: The report types listed in GrantSolutions are different than what the LITC Program uses. Annual is yearend and semi-annual is interim. 
LOW INCOME TAXPAYER CLINICS 133 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

 

 

INSTRUCTIONS FOR FORM 13424-A, LOW INCOME TAXPAYER CLINIC 

(LITC) GENERAL INFORMATION REPORT 

Form 13424-A, LITC General Information Report, is used to report all clinic outreach activities, educational 

activities, consultations, referrals, tax return and other document preparation, volunteer activities, work performed 

by students, and professional education activities conducted during the reporting period. 

The Program Office uses the information reported on this form and the other reporting forms to determine 

the scope of services provided by clinics. Data from all clinics is totaled to provide program-wide statistical 

information about services provided to low-income and ESL taxpayers. Please be careful to follow the instructions 

for this form and to report all information completely and accurately. If additional room is necessary to provide 

details about the activities reported on this form, include such details on Form 13424-N, Low Income Taxpayer 

Clinic (LITC) Program Narrative, where appropriate. 

Specific Instructions for Completing the Form 

Outreach Activities 

The system will navigate to the screen below when the Form 13424-A is selected on the Form Selection screen. 

Report all outreach activities conducted during the reporting period in this section. 

Outreach activities are efforts designed to publicize the clinic and its services. Outreach activities may involve 

direct communication with taxpayers or may be accomplished indirectly through other organizations or groups 

that assist low-income or ESL taxpayers. Examples of outreach activities include a presentation about clinic 

services made to taxpayers, a campaign to distribute clinic flyers or other marketing materials to local social 

services organizations, or a table staffed at a community event such as a fair, forum, or meeting to inform the 

public about clinic services. 

LITCs are encouraged to identify particular linguistic populations, geographic service areas, or other segments of 

the low-income and ESL taxpayer community in which to focus outreach efforts. 

Determine whether to record an outreach activity on line 1A, 1B, or 1C by looking to the primary intended 

audience of the activity, rather than the actual attendees. Outreach activities primarily intended to reach ESL 

taxpayers should be reported on line 1A, activities primarily intended to reach non-ESL taxpayers in general 
134 LOW INCOME TAXPAYER CLINICS

should be reported on line 1B, and those intended for other organizations that assist ESL or low-income taxpayers 

should be reported on line 1C. Report each outreach activity only once on line 1A, 1B, or 1C. 

A single outreach activity may span multiple days. For example, if a clinic staffs a booth for multiple days at a 

weeklong event, that should be counted as one outreach activity. Additional details about the extent of such efforts 

can be included in the Program Narrative. A campaign that involves sending the same or similar letters to multiple 

recipients should be counted as a single outreach activity. 

i. Line 1A. Report on this line the number of outreach activities conducted for ESL taxpayers; 

ii.	 Line 1B. Report on this line the number of outreach activities conducted for non-ESL taxpayers; 

iii.	 Line 1C. Report on this line the number of outreach activities conducted for other organizations that 

assist ESL or low-income taxpayers. For example, the clinic meets with board members of a local church 

in preparation for the church’s upcoming clothing drive to benefit the homeless. The clinic requests that 

the church inform low-income and ESL taxpayers about the clinic’s services. The clinic would record those 

efforts as a single outreach activity on line 1C; and 

iv.	 Line 1D. The amount on this line is the total number of outreach activities conducted during the 

reporting period. The system will total the sums of lines 1A, 1B, and 1C automatically. A description of the 

activities must be included on Form 13424-N, LITC Program Narrative Report, line 2.iv. See Publication 

3319 for additional information. 

Educational Activities 

Report all educational activities conducted during the reporting period in this section. 

Educational activities are programs designed to inform ESL or low-income taxpayers about their rights and 

responsibilities as taxpayers, as well as tax issues of particular significance to the intended audience. Educational 

activities may also be conducted for other organizations that assist low-income or ESL taxpayers. 

To be considered an educational activity, information about a specific tax topic or topics must be conveyed 

to the audience. Examples of educational activities include a presentation about tax collection issues made to 

ESL taxpayers, a workshop for low-income workers about how to properly complete a Form W-4, Employee’s 

Withholding Certificate, or the distribution of written materials about EITC eligibility rules to community case 

workers of a social services organization for them to share with their clients. 

Clinics may also use virtual platforms to deliver educational programs and may count them as educational 

activities for the purposes of LITC reporting when there is a way for participants to be counted and for the 

speaker and participants to interact. 

Determine whether to record an educational activity on line 2A, 2B, or 2C by looking to the primary intended 

audience of the activity, rather than the actual attendees. Educational activities primarily intended to reach ESL 

taxpayers should be reported on line 2A, activities primarily intended to reach non-ESL taxpayers should be 

reported on line 2B, and those intended for other organizations that assist ESL or low-income taxpayers should 

be reported on line 2C. Report each educational activity only once on line 2A, 2B, or 2C. Do not include any 

activities recorded as Outreach on lines 1A through 1D. 
LOW INCOME TAXPAYER CLINICS 135 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

v.	 Line 2A. Report on this line the number of educational activities conducted for ESL taxpayers; 

vi.	 Line 2B. Report on this line the number of educational activities conducted for non-ESL taxpayers; 

vii.	 Line 2C. Report on this line the number of educational activities conducted for other organizations that 

assist ESL or low-income taxpayers; and 

viii.	 Line 2D. The amount on this line is the total number of educational activities conducted during the 


reporting period. The system should total the sums of lines 2A, 2B, and 2C automatically.
 

NOTE: The program goal for educational activities to low-income and ESL taxpayers is the sum of lines 2A and 2B. 

i.	 Line 3A. Report on this line the total number of attendees at all educational activities conducted for ESL 

taxpayers during the reporting period; 

ii.	 Line 3B. Report on this line the total number of attendees at all educational activities conducted for nonESL taxpayers during the reporting period; 

iii.	 Line 3C. Report on this line the total number of attendees at all educational activities conducted for other 

organizations that assist ESL or low-income taxpayers during the reporting period; and 

iv.	 Line 3D. The amount on this line is the total number of attendees at all educational activities conducted 

during the reporting period. The system should total the sums of lines 3A, 3B, and 3C automatically. 

NOTE: The program goal for low-income and ESL taxpayers reached in educational activities is the sum of lines 

3A and 3B. 
136 LOW INCOME TAXPAYER CLINICS

i.	 Line 4. List the topics that were covered during the educational activities reported on lines 2A through 2C. 

Input one title per line in section 4 and click on the Add button to enable the additional line option. Do 

not repeat the same topic on multiple lines. If a topic was presented at multiple events, you may list the 

number of times the topic was presented. For example, you may enter EITC x 4 to indicate you held four 

EITC presentations during the reporting period. 

i.	 Line 5. List the languages, other than English, in which educational activities were conducted. Input one 

language per line and click on the Add button to enable the additional line option. 

Educational activities are intended to have attendees. Do not report the posting of educational materials to a 

website or the distribution of educational materials via social media as educational activities. These activities are 

properly reported on Form 13424-C, LITC Advocacy Information Report, in Part II, Published Materials. 

Consultations 

Report all consultations conducted during the reporting period in this section. 

A consultation is a discussion with a taxpayer designed to provide advice or counsel about a specific tax matter 

that does not result in representation of the taxpayer. If a clinic undertakes representation of a taxpayer before 

a court or the IRS, then that matter should not be reported on this form as a consultation, but rather reported 

as a case on Form 13424-K, LITC Case Information Report. A technical assistance consultation is a discussion 

with a practitioner or other service provider designed to give brief advice about a tax issue. For example, if a 

clinic staff member addresses a tax-related question for a staff member of another legal services organization, that 

communication should be counted as a technical assistance consultation. See Section VI.C.viii, Technical Assistance 

Consultation. 

i.	 Line 6A. Report on this line the number of consultations conducted with ESL taxpayers; 

ii.	 Line 6B. Report on this line the number of consultations conducted with non-ESL taxpayers; and 
LOW INCOME TAXPAYER CLINICS 137 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

iii. Line 6C. The amount on this line is the total number of consultations conducted with taxpayers during 

the reporting period. The number reported on this line should equal the total of lines 6A and 6B. 

i.	 Line 7. Report on this line the number of technical assistance consultations conducted with a practitioner 

or other service provider during the reporting period. A description of the types of issues and questions 

addressed in the consultations must be included in the Program Narrative on Form 13424-N, line 2.v. See 

Publication 3319 for additional information. 

Referrals 

Report the number of cases reported on Form 13424-K, line 1C, for which the Taxpayer Advocate Service (TAS) 

provided assistance during the reporting period at the request of the LITC. 

NOTE: A description of the reasons for seeking TAS assistance must be included in the Program Narrative on 

Form 13424-N, line 2.vi. If you receive case referrals from TAS and wish to report them, see Form 13424-N, 

line 2.ix. 

Tax Returns and Other Documents 

An LITC can provide assistance with a federal tax return, a claim for refund, or an Individual Taxpayer 

Identification Number (ITIN) application if such assistance is necessary to resolve a dispute with the IRS or is 

an ancillary part of the LITC’s ESL education. The clinic may not charge a fee (even if it is a nominal fee) for the 

preparation of a tax return or a claim for refund. An LITC or an individual associated with an LITC that adheres 

to this policy is specifically excluded from the definition of a “Tax Return Preparer” as set forth in Treas. Reg. § 

301.7701-15(f). 

i.	 Line 9A. Report on this line the number of tax returns prepared ancillary to ESL activities. Ancillary tax 

return preparation must be incidental to the clinic’s primary mission and the program may only provide 

such assistance if the request to do so arises from the clinic’s primary outreach and educational activities; 

ii.	 Line 9B. Report on this line the number of tax returns prepared to resolve a controversy; and 

iii.	 Line 9C. The amount on this line is the total number of tax returns prepared during the reporting period. 

The system should total the sums of lines 9A and 9B automatically. 
138 LOW INCOME TAXPAYER CLINICS

i.	 Line 10. Report on this line the number of ITIN applications (Form W-7) prepared during the reporting 

period. 

Do not count tax returns that are prepared but not submitted to the IRS. Do not report any state tax returns that 

were prepared, only federal returns. 

Volunteer Activities 

i. Line 11. Select the appropriate button to indicate whether the clinic maintains a pro bono panel to which 

taxpayers can be referred for controversy representation; 

ii. Lines 12A-F. In this section, report on the number of volunteers who provided service to the clinic during 

the reporting period. Count each volunteer only once, based on the category of services the volunteer 

typically provides to the clinic. For example, if an enrolled agent is multilingual and also provides 

translation services, you may note that in the Program Narrative on Form 13424-N, line 2.ix; however, the 

clinic should only count that volunteer as either an enrolled agent or an interpreter/translator, not both. 

Do not include any individuals receiving compensation from the clinic or any students receiving academic 

credit; 

iii. Line 12G. The amount on this line is the total number of volunteers. The number reported on this line 

should equal the total of lines 12A-12F and should be an accurate count of all individuals who volunteered 

at the clinic during the reporting period. Only include volunteers who provided service during the 

reporting period and whose hours are included on the line 13 total; and 

iv. Line 13. Report on this line the total number of service hours provided by volunteers during the reporting 

period. Form 13424-F, Volunteer/Pro Bono Time Reporting, is available on the LITC Toolkit to assist you 

in tracking volunteer hours. Form 13424-F is for internal record keeping by the clinic only and should not 

be submitted to the LITC Program Office, unless the grant recipient chooses to provide it to substantiate 

volunteer in-kind time used as matching funds. Do not include time spent by any individuals receiving 

compensation from the clinic or any students receiving academic credit. 
LOW INCOME TAXPAYER CLINICS 139 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Student Representation 

i.	 Line 14. Report on this line the number of students that worked at the clinic during the reporting period 

who were authorized to practice before the IRS under a special appearance authorization; and 

ii.	 Line 15. Report on this line the number of students who worked at the clinic during the reporting period 

who received academic credit for their clinic work. 

Professional Education Activities 

Report on accredited Continuing Professional Education (CPE) or Continuing Legal Education (CLE) 

presentations the clinic conducted during the reporting period in this section. 

i.	 Line 16. Report on this line the total number of CPE or CLE credits available through presentations held 

during the reporting period. For example, if during the reporting period the clinic held three lunchtime 

presentations offering one hour of CLE credit each, and one day-long presentation, offering eight hours of 

CLE credit, the clinic would enter 11 on this line; and 

ii.	 Line 17. Report the topics covered during CPE or CLE presentations. Input one title per line in section 17 

and click on the Add button to enable additional lines. Do not repeat topics on multiple lines. If a topic 

was repeated throughout multiple presentations, you may list the number of times the topic was presented. 

For example, you may enter EITC x 4 to indicate you held four CPE or CLE presentations on the EITC 

during the reporting period. 

Report only professional educational activities dealing with issues affecting low-income or ESL taxpayers. 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
140 LOW INCOME TAXPAYER CLINICS

 

 

INSTRUCTIONS FOR FORM 13424-B, LOW INCOME TAXPAYER CLINIC 

(LITC) CASE ISSUES REPORT (YEAR-END ONLY) 

Form 13424-B, LITC Case Issues Report, is used to report issues worked by a clinic while representing taxpayers 

in controversy cases that were open at any time during the reporting period, including cases carried over from 

the previous grant year. The issues reported should relate to all cases reported on Form 13424-K, LITC Case 

Information Report, line 1C. The Program Office uses the information reported on this form and the other 

reporting forms to determine the scope of services provided by clinics. Data from all clinics is totaled to provide 

program-wide statistical information about services provided to low-income and ESL taxpayers. Be careful to 

follow the instructions for this form and to report all information completely and accurately. 

Specific Instructions for Completing the Form 

A case arises from a controversy between an individual and the IRS concerning the determination, collection, or 

refund of any tax, penalties, additions to tax, or interest and includes any proceeding brought by the taxpayer 

under Title 26. A controversy includes a dispute related to the tax provisions of the Affordable Care Act. A 

controversy does not include a federal criminal tax matter but may include certain civil actions arising under the 

Internal Revenue Code (IRC), for example those arising under IRC §§ 7431–7435. 

A case may involve more than one issue. An issue is counted only if the clinic undertakes representation on behalf 

of the taxpayer, the issue is disputed between the taxpayer and the IRS, and the clinic takes steps to resolve the 

dispute. An issue is counted and reported on this form only once for each case, regardless of the number of tax 

years involved in the dispute. See Example 2 below. An issue is not counted on this form when the clinic only 

discusses the issue with the taxpayer and provides advice but does not take steps to advocate on behalf of the 

taxpayer to the IRS or a court. See Example 3 below. 

Example 1: Reporting Case Issues 

Clinic A represented ten taxpayers in EITC examination cases during the reporting period. Each case has 

four issues in dispute: head of household filing status, dependency exemptions, child tax credit, and EITC 

eligibility. Clinic A would enter 10 on lines 30, 31, 37, and 38. 

Example 2: Reporting Case Issues 

Clinic B represented a taxpayer in a collection case involving six tax years. Clinic B advocated for the 

taxpayer’s accounts to be placed in currently not collectible status. Clinic B would count this case as one 

currently not collectible issue on line 60, regardless of the number of tax years in dispute. (This case would 

be included in the total on line 6 of Form 13424-K for cases having more than one tax year in dispute.) 

Example 3: Reporting Case Issues 

Clinic C represented a taxpayer in a collection case that involved negotiating with the IRS to establish an 

installment agreement. In the course of the representation, Clinic C discussed with the taxpayer various 

collection alternatives, including an Offer in Compromise (OIC). The installment agreement issue would 

be counted as an issue and reported on line 58 because Clinic C negotiated the installment agreement 

on behalf of the taxpayer. The OIC discussion would not be counted as an issue and reported on line 59 

because Clinic C did not prepare or submit to the IRS an OIC on behalf of the taxpayer. 
LOW INCOME TAXPAYER CLINICS 141 

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V VI APPENDIX B GLOSSARY INDEX

Income Issues 

Lines 1-14. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular income issue. For example, a dispute involving the amount or 

classification of a taxpayer’s wages would be reported on line 1, Wages. 

Deduction Issues 
142 LOW INCOME TAXPAYER CLINICS

Lines 15-27. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular deduction issue. For example, a dispute involving the allowance of 

an adjustment for alimony would be reported on line 15, Alimony. 

Credit Issues 

Lines 28-34. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular credit issue. For example, a dispute involving a taxpayer’s eligibility 

for an adoption credit would be reported on line 34, Other Credits. 

Status Issues 

Lines 35-44. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular status issue. For example, a dispute involving the taxpayer’s eligibility 

to claim head of household filing status would be reported on line 37, Filing Status. 
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Tax/Refund/Return/Statute of Limitations Issues

Lines 45-52. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular tax or refund or statute of limitations issue. For example, a dispute 

involving suspected fraud or misconduct on the part of a return preparer would be reported on line 46, Suspected 

Return Preparer Fraud. 

Penalty and Addition to Tax Issues 

Lines 53-56. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular penalty issue. For example, a dispute involving the assessment of an 

accuracy-related penalty would be reported on line 54, Other Civil Penalties. 
144 LOW INCOME TAXPAYER CLINICS

Collection Issues 

Lines 57-62. Report on the appropriate line the number of cases worked during the reporting period where the 

taxpayer’s controversy involved the particular collection issue. For example, a dispute involving the release of a levy 

on a taxpayer’s Social Security benefits would be reported on line 62, Levies. 

Total. Report the total number of issues reported on lines 1–62. The system should total the sum automatically. 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
LOW INCOME TAXPAYER CLINICS 145 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

 

 

INSTRUCTIONS FOR FORM 13424-C, LOW INCOME TAXPAYER CLINIC 

(LITC) ADVOCACY INFORMATION REPORT (YEAR-END ONLY) 

Form 13424-C, LITC Advocacy Information, is used to report information about certain advocacy work the 

clinic performed during the reporting period. This form is used to report all systemic advocacy issues submitted, 

written materials published, television and radio appearances made, and public service announcements aired 

during the reporting period. 

The LITC Program Office uses the information reported on this form and the other reporting forms to determine 

the scope of services provided by clinics. Data from all clinics is totaled to provide program-wide statistical 

information about services provided to low-income and ESL taxpayers. Please be careful to follow the instructions 

for this form and report all information completely and accurately. If additional space is necessary to provide 

details about the activities reported on this form, include those details on Form 13424-N, Low Income Taxpayer 

Clinic (LITC) Program Narrative Report, Item 2,ix. 

Specific Instructions for Completing the Form 

Systemic Advocacy Submissions 

Report in this section all systemic issues that relate to low-income or ESL taxpayers that were submitted to the 

Systemic Advocacy Management System (SAMS) during the reporting period. 

Include the SAMS issue number, the name of the individual who made the submission, the date of each 

submission, and a brief description of the issue described in the submission. The SAMS website is available at 

www.irs.gov/advocate/systemic-advocacy-management-system-sams. 
146 LOW INCOME TAXPAYER CLINICS

Published Materials 

Report in this section all written materials published during the reporting period to educate low-income or ESL 

taxpayers or to bring awareness to the public about the clinic, LITC Program, or tax issues that affect low-income 

or ESL taxpayers. 

Include the posting of educational materials to a website or the distribution of educational materials via social 

media. Select from the list the source where the material was published. If the publication was released in multiple 

formats (i.e., in a magazine and on a website) check one box and list the other formats on Form 13424-N, LITC 

Program Narrative Report, line 2.ix. 

Include the author’s name, the publication date, the title of the publication or website, the title of the work, and a 

brief description of the work (4,000 character limit). 

Click Add to report additional publications. 

Television and Radio Appearances 

Report in this section all television and radio appearances produced by or featuring clinic staff and broadcast 

during the reporting period to educate low-income or ESL taxpayers or to bring awareness to the public about the 

clinic, LITC Program, or tax issues that affect low-income or ESL taxpayers. 

If the broadcast was released in multiple formats or on multiple channels, list the other formats on Form 

13424-N, LITC Program Narrative Report, line 2.ix. 

Include the airing dates of each segment, a reasonable estimate of the number of listeners or viewers, the topic 

of the discussion or on-air piece, the names of any clinic representatives involved in the appearances, and a brief 

description of the topic discussed on-air. 

Click Add to report additional appearances. 
LOW INCOME TAXPAYER CLINICS 147 

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V VI APPENDIX B GLOSSARY INDEX

Public Service Announcements 

Report all public service announcements (PSAs) produced by or featuring clinic staff and broadcasts during the 

reporting period written to educate low-income or ESL taxpayers or bring awareness to the public about the 

clinic, LITC Program, or tax issues that affect low-income or ESL taxpayers. 

Include the number of times each segment aired, a reasonable estimate of the number of listeners or viewers, the 

topic of the discussion or on-air piece, the names of any clinic representatives involved in the appearances, and a 

brief description of the topic discussed on-air. 

Click Add to report additional PSAs. 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
148 LOW INCOME TAXPAYER CLINICS

 

 

INSTRUCTIONS FOR FORM 13424-K, LOW INCOME TAXPAYER CLINIC 

(LITC) CASE INFORMATION REPORT 

Form 13424-K, LITC Case Information Report, is used to report information about the work performed by a 

clinic while representing taxpayers in controversy cases that were open at any time during the reporting period, 

including cases carried over from the previous grant year. The information reported should relate to all cases 

reported on line 1C of this form, unless otherwise instructed. The Program Office uses the information reported 

on this form and the other reporting forms to determine the scope of services provided and the breadth of work 

done by clinics. Data from all clinics is totaled to provide program-wide statistical information about services 

provided to low-income and ESL taxpayers. Please carefully follow the instructions for this form and report all 

information completely and accurately. 

Specific Instructions for Completing the Form 

A case arises from a controversy between an individual and the IRS concerning the determination, collection, or 

refund of any tax, penalties, additions to tax, or interest, including any proceeding brought by the taxpayer under 

Title 26. A controversy includes a dispute related to the tax provisions of the Affordable Care Act. A controversy 

does not include a federal criminal tax matter but may include certain civil actions arising under the Internal 

Revenue Code, for example those arising under IRC §§ 7431–7435. 

A case is counted and reported in inventory when a taxpayer retains the clinic to represent him or her in an 

advocacy capacity before the IRS or a federal court and the clinic takes steps to begin the case, including 

developing a plan for advocacy. Case information continues to be counted and reported on this form each period 

until the case is closed. 

NOTE: Matters involving fact-finding or advice only are not cases; these matters are counted and reported as 

consultations on Form 13424-A, LITC General Information Report. 

If a taxpayer’s case requires the clinic to advocate to more than one IRS function or court or involves more than 

one tax year, it is still counted and reported as a single case on Form 13424-K. The clinic can capture the breadth 

of the work done in the case by including the case in the numbers reported on line 5 (cases involving matters 

worked in more than one IRS function or court) or line 6 (cases involving more than one tax year) of this form 

and by reporting all of the relevant tax issues on Form 13424-B, LITC Case Issues Report. Additional information 

may also be included in the Program Narrative on Form 13424-N, LITC Program Narrative Report, line 2.ix. 
LOW INCOME TAXPAYER CLINICS 149 

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V VI APPENDIX B GLOSSARY INDEX

Case Inventory 

Report in this section the volume of case inventory. 

i.	 Line 1A. Report on this line the number of cases that were worked in the previous year that remained open 

as of January 1. This number should be the same as the ending case inventory reported on Form 13424-K, 

line 1D, of the Year-end report submitted for the previous grant year; 

ii.	 Line 1B. Report on this line the number of new cases that were opened during the reporting period; 

iii. Line 1C. The sum of lines 1A and 1B will calculate automatically; 

iv. Line 1D. Report on this line the number of cases closed during the reporting period; and 

v.	 Line 1E. The system will automatically calculate the ending inventory. 
150 LOW INCOME TAXPAYER CLINICS

Cases Worked 

Report in this section the IRS function or federal court where cases are being worked. 
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V VI APPENDIX B GLOSSARY INDEX

If a case was open at the end of the reporting period, indicate the IRS function or federal court where the case is 

being addressed as of the end of the reporting period. 

If a case was closed during the reporting period, indicate the IRS function or federal court where the case was 

handled immediately before closing. Each case should be counted only once during a reporting period; however, a 

case that remains open beyond a single reporting period may be properly reported as being handled by a different 

function from one reporting period to the next. Thus, a case may be reported as being handled by a different 

function in the Year-end Report than was reported in the Interim Report. If a single case is being addressed by 

more than one IRS function at the end of a reporting period, report that case where the primary issue is being 

addressed. 

The total reported in this section must equal the total number of cases worked during the reporting period as 

reported on line 1C. 

Example 1: Reporting Case Work 

Clinic A is representing a taxpayer in a dispute involving a proposed deficiency. On May 15, Clinic 

A submitted correspondence to the IRS’s Correspondence Exam unit on behalf of the taxpayer. On 

August 1, the IRS issued a Notice of Deficiency. On November 20, Clinic A filed a petition in the U.S. 

Tax Court. On its Interim Report, Clinic A would report the case on line 2E because the case was being 

addressed in the Correspondence Exam Unit as of June 30. On its Year-end Report, Clinic A would 

report the case on line 2U because the case was being addressed in the U.S. Tax Court as of December 31. 

Example 2: Reporting Case Work 

Clinic B is representing a taxpayer in a dispute involving eligibility for EITC for two tax years. At the 

close of the reporting period, one tax year is being addressed in the U.S. Tax Court and the other tax year 

is being addressed by the IRS in an audit reconsideration. The Clinic B may report the case on either line 

2I or 2U but may not report the case on both lines. Clinic B has discretion to decide whether to report 

the case on line 2I or 2U, taking into account whatever factors it deems important to help the Program 

Office better understand the status of the casework performed as of the end of the reporting period. 
152 LOW INCOME TAXPAYER CLINICS

Additional Case Information 

Report additional information about cases worked during the reporting period. Lines 3 and 4 relate to new cases 

opened during the reporting period, as reported on line 1B. Lines 5 through 10 apply to all cases worked during 

the reporting period, as reported on line 1C. 

i.	 Line 3. Report on this line the number of new cases opened during the reporting period in which the 

amount in controversy exceeds $50,000 for any tax year. A clinic may represent a taxpayer in a case in 

which the amount in controversy exceeds $50,000. However, the clinic must include an explanation of why 

each case was accepted for representation on Form 13424-N, LITC Program Narrative Report, line 2.vii. 

ii.	 Line 4. Report on this line the number of new cases opened during the reporting period for taxpayers 

whose income exceeds 250 percent of Federal Poverty Guidelines; and 

iii.	 Line 5. Report on this line the number of cases worked during the reporting period where the 

representative advocated to more than one IRS function or federal court. 

Example 1: Reporting Additional Case Details 

Clinic A is representing a taxpayer in a collection matter in which the IRS is levying the taxpayer’s Social 

Security benefits. The clinic agrees to represent the taxpayer and contacts the Automated Collection 

System (ACS) to prove financial hardship, request the levy be released, and have the taxpayer’s account 

placed in currently not collectible status. The clinic later assists the taxpayer in submitting an OIC. Clinic 

A should include this case among the number reported on line 5 because the clinic worked the case in 

both the ACS and OIC units. 

Example 2: Reporting Additional Case Details 

Clinic B is representing a taxpayer in a dispute involving eligibility for the EITC for two tax years. At the 

close of the reporting period, one tax year is being addressed in the U.S. Tax Court and the other tax year 

is being addressed by the IRS in an audit reconsideration. Clinic B should include this case among the 

number reported on line 5 because the clinic is working the case both in a federal court and Examination. 

iv.	 Line 6. Report on this line the number of cases worked during the reporting period in which the clinic 

represented a taxpayer in a dispute involving more than one tax year; 

v.	 Line 7. Report on this line the number of cases worked during the reporting period in which the clinic 


represented an ESL taxpayer;
 

vi.	 Line 8. Report on this line the number of cases worked during the reporting period in which the clinic 

represented both the taxpayer and the taxpayer’s spouse with regard to a joint tax liability; 
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V VI APPENDIX B GLOSSARY INDEX

vii.	 Line 9. Report on this line the number of cases worked during the reporting period in which the 

clinic used a volunteer to represent the taxpayer. Do not count as volunteers any individuals receiving 

compensation from the clinic or any students receiving academic credit for their work at the clinic; and 

viii.	 Line 10. Report on this line the number of cases worked during the reporting period in which the clinic 

represented a taxpayer on state or local tax matters related to a federal tax controversy. 

Tax Court Activities 

i.	 Line 11. Select Yes or No to indicate whether the clinic participates in the U.S. Tax Court Clinical 

Program. If Yes is selected, list the “place of trial” city or cities served. Input one location per line and click 

on Add to include additional locations; 

ii. Line 12. Report on this line the number of cases reported on line 1C for which the clinic entered an 

appearance to represent the taxpayer in the U.S. Tax Court, whether through filing an entry of appearance 

or via a petition submitted by the clinic; 

iii. Line 13. Report on this line the number of cases reported on line 1C for which the clinic represented a 

taxpayer in a case filed in the U.S. Tax Court, but where no entry of appearance was submitted by the 

clinic. For example, if a clinic staff attorney represented a client who filed a petition in the U.S. Tax Court 

and the attorney negotiated a settlement with the IRS but did not enter an appearance with the Tax Court, 

include this case among the number reported on line 13; and 

iv. Line 14. Report on this line the number of informal consultations conducted with taxpayers in the U.S. 

Tax Court during the reporting period. Representation of taxpayers reported on lines 12 and 13 should 

not be reported on this line. For example, if a clinic staff attorney assisted a taxpayer at a U.S. Tax Court 

calendar call by providing advice to the taxpayer or acting as a communicator or mediator between the 

parties, but does not represent the taxpayer, such assistance would be counted as an informal consultation 

and reported on line 14. 
154 LOW INCOME TAXPAYER CLINICS

Closed Case Outcomes 

Report in this section the outcomes of cases that were closed during the reporting period. Information reported in 

this section should only relate to cases reported on line 1D. The information reported in this section will help the 

Program Office better understand the impact of the clinic’s casework. 

i.	 Line 15A. Report on this line the number of cases closed during the period in which the taxpayer was 

brought into filing compliance during the representation. Cases where a taxpayer was successfully assisted 

or referred for assistance with return preparation to resolve a collection matter can be included here; 

ii.	 Line 15B. Report on this line the number of cases closed during the period in which the taxpayer was 

brought into collection compliance during the representation. Cases where the taxpayer paid tax liabilities 

in full, entered an approved installment payment plan, was placed in currently not collectible status, or 

obtained an OIC can be included here; 

iii.	 Line 15C. Report on this line the total dollars in tax refunds that were paid to taxpayers whose cases were 

closed during the reporting period, rounded to the nearest whole dollar. Do not include refunded dollars 

that were offset against any other outstanding tax liability. This amount may include all refunds issued 

to the taxpayer during the representation that relate to the tax years in dispute. Include state and local 

tax refunds if the clinic represented taxpayers before those agencies on a matter related to the federal tax 

controversy; and 

iv.	 Line 15D. Report on this line the total dollar impact in tax liabilities, penalties, and interest to taxpayers 

whose cases were closed during the reporting period, rounded to the nearest whole dollar. Include an 

abatement of tax, penalties, or interest, a reduction in a proposed deficiency, the amount of innocent 

spouse relief obtained, the difference between the full amount owed and the total amount to be paid on 

an accepted OIC, and similar items. Do not include amounts placed in currently not collectible status. 

Include the total dollar impact in state and local tax liabilities, penalties, and interest to taxpayers if the 

clinic represented taxpayers before those agencies on a matter related to the federal tax controversy. 

Example: Reporting Case Outcomes 

A clinic represented a taxpayer facing a proposed deficiency of $3,000. After review of the facts, the clinic 

determined that the IRS failed to credit $4,000 in withholding. The $3,000 liability was abated in full, 

and the taxpayer received a cash refund of $1,000. The clinic should report $1,000 on line 15C, and 

$3,000 on line 15D. 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
LOW INCOME TAXPAYER CLINICS 155 

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V VI APPENDIX B GLOSSARY INDEX

INSTRUCTIONS FOR FORM 13424-L, STATEMENT OF GRANT 

EXPENDITURES AND NARRATIVE EXPLANATIONS 

Form 13424-L, Statement of Grant Expenditures and Narrative Explanations, is used to report how federal grant 

funds and matching funds were spent by the clinic during the reporting period. This form is also used to report 

a narrative explanation of how each expense amount was calculated and the sources and valuation of matching 

funds. All expenses must be reasonable, necessary, and allocable to the LITC grant. See 2 CFR Part 200 for 

additional guidance on costs and matching funds. 

NOTE: Grant expenditure amounts must also be reported on Standard Form 425 (described below). 

Specific Instructions for Completing the Form 

* The instructions provided on page 165-169 cannot be revised without OMB approval. Therefore, recent changes 

to 2 CFR 200 regarding the increase to the Equipment threshold amount and the de minimis rate will not be 

reflected on these pages. 

Detailed Budget Worksheet 

The system will navigate to the screen below when the Form 13424-L is selected on the Form Selection screen. 

Each line item does not require a dollar-for-dollar match, but the total matching funds must equal or exceed the 

total federal funds expended. 

The total amount reported on this form for expenditure of federal funds (line K, Federal column) must be the 

amount of federal funds spent during the reporting period; do not include any amounts drawn from the award 

using the Payment Management System (PMS), but not spent. PMS is operated by the Department of Health 

and Human Services. 

Grant Expenditures Narrative Explanation 

This section requires more detailed information about the clinic’s expenditures. 

Each letter of the Grant Expenditures Narrative Explanation corresponds to an expense category in the Detailed 

Budget Worksheet. The information provided in the narrative should be sufficiently detailed so that a reviewer 

can arrive at the same amounts listed on the Detailed Budget Worksheet by expense and by category (federal or 

match). 
156 LOW INCOME TAXPAYER CLINICS

Personnel 

Report salaries and wages that were paid to LITC staff. Do not include fringe benefits in this category (fringe 

benefits should be accounted for in Category B). In the explanation, list each staff member’s name, position, 

rate of pay, and time devoted to clinic activities (hourly wage and number of hours of service, or annual salary 

and percentage of annual salary). State the portion of each staff member’s salary or wages paid from federal and 

matching funds, as well as the source of the matching funds. Volunteer in-kind services should not be included in 

the Personnel category. They must be included in Category H, Other Expenses. 

Calculate each clinic staff member’s full-time equivalent (FTE). Take the staff member’s total hours worked for 

the clinic and divide it by total hours in the reporting period. For staff assigned to LITC activities on a percent of 

total working hours, convert the applicable percentage into a decimal. 

NOTE: If a staff member is full-time with the organization but only a partial FTE for the clinic, multiply the 

FTE times the full-time salary to arrive at the proper amount to include as a personnel expense. 

Calculate the personnel expense for each staff member. Personnel expense can be calculated as a percent of total 

time/FTE multiplied by salary or by multiplying the number of hours worked by the applicable hourly rate. 

Determine and list the dollar amount attributable to federal and match. List sources of match in the comment 

section. 

Input one person per line in the personnel narrative section. Click on the Add button to enable the additional line 

option. 

Fringe Benefits 

Report fringe benefits that were paid on behalf of LITC staff whose wages and salaries are reported in personnel 

costs (Category A above). In the explanation, state the fringe benefits rate(s), the items that constitute the fringe 

benefits, what portion was paid by federal funds and matching funds, and the source of matching funds. Identify 

the rate applicable to each staff position if varying rates apply by position. 

n	Show the formula (methodology) for calculating fringe benefits for each position listed in Category A; 

n	State what items are included in fringe benefits; 

n	Provide the dollar amount attributable to federal and match; and 

n	Indicate the source of matching funds. 
LOW INCOME TAXPAYER CLINICS 157 

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V VI APPENDIX B GLOSSARY INDEX

Travel 

Report travel costs, including costs associated with attendance at the annual LITC conference and other travel 

expenses directly related to conducting LITC business or activities. In the explanation, identify the travel costs 

listed, whether the costs were paid with federal or matching funds, and the source of the matching funds. 

Break down travel costs by category, such as transportation, hotel, meals, and incidental expenses, and mileage. If 

using a mileage rate, show the computation. 

Equipment 

Report the cost of equipment that was purchased by the clinic and used in operating an LITC Program. Donated 

equipment may be included as matching funds and must be valued at the fair market value of the property at the 

time of the donation. In the explanation, identify the equipment purchased or donated, whether the associated 

costs were paid using federal or matching funds, and the source of the matching funds. If there were third-party 

in-kind contributions of equipment, identify the equipment, the donor, and how the valuation was determined. 

Only equipment costing $10,000 or more is included in the category; equipment costing less must be included in 

Category E, Supplies. 

Supplies 

Report the cost of supplies and equipment costing less than $10,000 that were used in operating the LITC. 

Donated supplies may be included as matching funds and must be valued at the fair market value of the property 

at the time of the donation. In the explanation, identify: 

n	The value of supplies used; 

n	Whether the associated costs were paid using federal or matching funds; and 

n	Source of the matching funds. 

If there are third-party in-kind contributions of supplies, explain the amount of the supplies contributed and the 

valuation. 
158 LOW INCOME TAXPAYER CLINICS

Contractual 

Report the cost of rent, utilities, and other contracted items or services that were used in operating the clinic. 

Donated space may be included as matching funds and the value assigned may not exceed the fair rental value of 

comparable space. The explanation should identify: 

n	Nature of the expense; 

n	Whether the associated costs were paid using federal or matching funds; and 

n	Source of the matching funds. 

If a contracted item or service pertains to other programs in addition to LITC activities, only the portion 

directly attributable to LITC activities may be allocated to the LITC Program. The narrative must explain the 

methodology used to apportion costs between LITC activities and other programs. 

There are two acceptable methodologies for calculating federal funds allocable to indirect costs: 

n	Indirect Cost Rate Agreement 

i.	 Must be approved in advance; 

ii.	 Agreement must set forth cost items included in the rate; and 

iii.	 The clinic may not charge items included in the rate as separate expense items. 

n	De minimis 15 Percent Rate 

i.	 Rules are set forth in 2 CFR § 200.414(f); and 

ii.	 Clinics that use the de minimis rate to charge indirect costs must charge costs consistently across federal 

grants and may not double charge or inconsistently charge as both. 

For example, if a clinic is part of a larger organization that has an indirect cost rate agreement and the rental cost 

of the facility in which the clinic operates is included in the negotiated rate, then the clinic may not include the 

facilities cost under the Contractual Expense category. Similarly, if the clinic elects to use the de minimis rate to 

charge indirect costs on all its federal awards, no facilities and administration costs may be charged as direct costs. 

Construction 

This section has been disabled. No construction expenses are allowed. 
LOW INCOME TAXPAYER CLINICS 159 

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V VI APPENDIX B GLOSSARY INDEX

Other Expenses

Report all other direct costs that were incurred in operating a clinic that are not properly included in categories A 

through G. The value of volunteer in-kind services is included in this category as matching funds. The explanation 

should identify: 

n	The type of expense; 

n	Whether the cost was paid using federal or matching funds; and 

n	Source of the matching funds. 

The explanation must also disclose the rate or rates that were used to value volunteer in-kind services and the 

number of volunteer hours that were provided, categorized by type of service or volunteer. 

Indirect Costs 

Report indirect costs not directly related to the LITC Program but incurred as part of the general overhead and 

administration of the grant recipient. Indirect charges may be charged as a use of federal funds based upon an 

approved Indirect Cost Rate Agreement or the de minimis rate allowed under 2 CFR § 200.414(f). However, 

indirect charges may not be counted as matching funds and the rate may only be applied to the base paid with 

federal funds. 

The narrative explanation should identify the indirect cost rate, the base to which the rate was applied, and the 

computation for the indirect charges amount. Briefly summarize the expenses included in the indirect cost rate 

agreement. 

If indirect costs were charged to the LITC grant, no items that are included in the indirect cost rate or the de 

minimis rate may be charged as direct expenses. For example, if a clinic is part of a larger organization that has 

an Indirect Cost Rate Agreement and the rental cost of the facility in which the clinic operates is included in the 

negotiated rate, then the clinic may not include the facilities cost under the Contractual Expense category. Clinics 

that use the de minimis rate to charge indirect costs must charge costs consistently across federal grants and may 

not double charge or inconsistently charge as both. See Publication 3319 and 2 CFR § 200.414 for guidance on 

indirect charges. 

NOTE: The de minimis rate under 2 CFR § 200.414(f) of the Uniform Guidance, has changed from ten percent 

of MTDC to 15 percent for 2025. 
160 LOW INCOME TAXPAYER CLINICS

Matching Funds 

This section addresses matching funds from sources other than the federal government. 

Provide a narrative that includes an explanation of the sources and amounts of matching funds. The clinic must 

state explicitly that matching funds provided to the LITC Program were (1) not used as matching funds for any 

other federal program and (2) not funds received from any other federal grant unless specifically authorized by 

statute to be used as matching funds. 

n	List amount of match by source; and 

n	List total of all match funding. 

Input one source of matching funds per line. Click on the Add button to enable the additional line option. 

Returning Unused Grant Funds and Requesting Additional Grant Funds 

This section addresses returning grant funds and requesting additional funds at interim. 

If you are returning funds at interim, select the Yes button and provide a statement about why the funds are being 

returned. If you are returning funds at Year-end, select the Yes button but only provide a statement if the amount 

you are returning exceeds $500. The Year-end statement about returned funds should include the reason(s) why 

grant funds were not expended or made available for redistribution to other grantees at interim and whether this 

was due to a one-time occurrence or an ongoing issue. 

NOTE: A clinic must notify its assigned advocacy analyst when it identifies that it will not spend all the grant 

funds, and it is outside of the Interim and Year-end reporting submission times. Timely notification is important 

because the Program Office may be able to redistribute the unused funds to another clinic. 

For the Interim Report only, if the LITC grant award is less than $200,000, a clinic may request additional LITC 

grant funds for the current grant year (to be used before December 31). Select the Yes button and provide a 

statement indicating the amount of additional funds requested, the expense category or categories where the funds 

will be spent, and the amount and source of matching funds that will be provided if the additional funding is 

awarded. The total funds requested for the grant year may not exceed $200,000. See IRC § 7526(c)(2). 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
LOW INCOME TAXPAYER CLINICS 161 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Form 13424-L

(May 2018) 

Department of the Treasury - Internal Revenue Service 

Statement of Grant Expenditures 

OMB Number 

1545-1648 

Name of Low Income Taxpayer Clinic Grant Period 

From To

Expense Categories Federal Match Total

A. Personnel 

B. Fringe Benefits 

C. Travel 

D. Equipment 

E. Supplies 

F. Contractual 

G. Construction 

H. Other Expenses 

I. Total Direct Charges 

J. Indirect Charges 

K. Totals 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 

For Paperwork Reduction Act Notice, see Publication 3319. 
LOW INCOME TAXPAYER CLINICS

Page 2

Grant Expenditures Narrative Explanations
­

A. Personnel 

B. Fringe Benefits 

C. Travel 

D. Equipment 

E. Supplies 

F. Contractual 

G. Construction 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 

162 
LOW INCOME TAXPAYER CLINICS 163 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Page 3

H. Other Expenses 

I. Total Direct Charges 

J. Indirect Costs 

Matching Funds 

Unused Grant Funds 

Additional Funding Request (Interim Report ONLY) 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 
164 LOW INCOME TAXPAYER CLINICS

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Instructions for Form 13424-L, Statement of Grant Expenditures
­

Note: Interim and Year-End Reports, including this form (Form 

13424-L) may be released under the Freedom of Information Act 

(FOIA). In response to a FOIA request, the LITC Program Office 

will release these reports after appropriate redactions to ensure 

confidentiality of taxpayer information. 

Purpose 

Form 13424-L, Statement of Grant Expenditures, is used to 

report how federal grant funds and matching funds were spent 

by the clinic during the reporting period. This form is also used to 

report a narrative explanation of how each expense amount was 

calculated and the sources and valuation of matching funds. All 

expenses must be reasonable, necessary, and allocable to this 

grant. See Publication 3319 or 2 CFR Part 200 for guidance on 

costs and matching funds. 

Note: Grant expenditure amounts must also be reported on SF 

425. 

Reporting Requirements 

All clinics must complete this form. See Publication 3319 for 

additional information. 

Reporting Period 

Clinics are required to report on LITC activities twice for each 

grant year. The grant year is January 1 through December 31 for 

the year in which a grant award is received. An Interim Report is 

required to report expenditures incurred for the period from 

January 1 through June 30; a Year-End Report is required to 

report expenditures incurred for the entire grant year, the period 

from January 1 through December 31. 

Specific Instructions for Completing the Form 

Each line item does not require a dollar-for-dollar match, but the 

total matching funds must equal or exceed the total federal funds 

expended. 

The total amount reported on this form for expenditure of Federal 

funds (line K, Federal column) must be the amount of Federal 

funds spent during the reporting period; do not include any 

amounts drawn from the award using the Payment Management 

System (PMS), but not spent. The PMS is operated by the 

Department of Health and Human Services, Division of Payment 

Management. 

Grant Expenditures Narrative Explanation 

This section requires more detailed information about your 

LITC's expenditures. Each letter of the Grant Expenditures 

Narrative Explanation corresponds to an expense category in the 

Detailed Budget Worksheet. The information provided in the 

narrative should be sufficiently detailed so that a reviewer can 

arrive at the same amounts listed on the Detailed Budget 

Worksheet by expense and by category (federal or match). 

A. Personnel 

Report salaries and wages that were paid to LITC staff. Do not 

include fringe benefits in this category (fringe benefits should be 

accounted for in category B). In the explanation, list each staff 

member's name, position, rate of pay and time devoted to clinic 

activities (hourly wage and number of hours of service, or annual 

salary and percentage of annual salary). State the portion of 

each staff member's salary or wages paid from federal and 

matching funds, as well as the source of the matching funds. 

Volunteer in-kind services should not be included under the 

Personnel category. They must be included under category H, 

Other Expenses. 

Calculate each clinic staff member's full-time equivalent (FTE). 

Take the staff member's total hours worked for the clinic and 

divide it by total hours in the reporting period. For staff assigned 

to LITC activities on a percent of total working hours, convert the 

applicable percentage into a decimal. 

Note: If a staff member is full-time with the organization but only 

a partial FTE for the clinic, multiply the FTE times the full-time 

salary to arrive at the proper amount to include as a personnel 

expense. 

Calculate the personnel expense for each staff member. 

Personnel expense can be calculated as a percent of total time/ 

FTE multiplied by salary, or by multiplying the number of hours 

worked by the applicable hourly rate. 

Determine and list out the dollar amount attributable to federal 

and match. List sources of match in the comment section. 

B. Fringe Benefits 

Report fringe benefits that were paid on behalf of LITC staff 

whose wages and salaries are reported in personnel costs 

(category A above). In the explanation state the fringe benefits 

rate(s), the items that constitute the fringe benefits, what portion 

was paid by federal funds and matching funds, and the source of 

matching funds. Identify the rate applicable to each staff position 

if varying rates apply by position. 

• Show the formula (methodology) for calculating fringe 

benefits for each position listed in Category A; 

• State what items are included in fringe benefits; 

• Provide the dollar amount attributable to federal and match; 

and

• Indicate the source of matching funds. 

C. Travel 

Report travel costs, including costs associated with attendance 

at the annual LITC conference and other travel expenses directly 

related to conducting LITC business or activities. In the 

explanation, identify: 

• The travel costs listed; 

• Whether the costs were paid with federal or matching funds; 

and

• The source of the matching funds. 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 
LOW INCOME TAXPAYER CLINICS 165 

APPENDIX B

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V VI APPENDIX B GLOSSARY INDEX

 

 

 

 

 

 

 

 

 

Page 5

Please break down travel costs by category, such as 

transportation, hotel, meals, and incidental expenses (MIE), and 

mileage. If using a mileage rate, show the computation. 

D. Equipment 

Report the cost of equipment that was purchased by the clinic 

and used in operating an LITC program. Donated equipment 

may be included as matching funds and must be valued at the 

fair market value of the property at the time of the donation. In 

the explanation, identify: 

• The equipment purchased or donated; 

• Whether the associated costs were paid using federal or 

matching funds; and 

• The source of the matching funds. 

If there were third-party in-kind contributions of equipment, 

identify the equipment, the donor, and the how the valuation was 

determined. Only equipment costing $5,000 or more is included 

in the category; equipment costing less is included in Category E. 

E. Supplies 

Report the cost of supplies and equipment costing less than 

$5,000 that were used in operating the LITC. Donated supplies 

may be included as matching funds and must be valued at the 

fair market value of the property at the time of the donation. In the 

explanation, identify: 

• The value of supplies used; 

• Whether the associated costs were paid using federal or 

matching funds; and 

• The source of the matching funds. 

If there are third-party in-kind contributions of supplies, explain 

the amount of the supplies contributed and how the valuation was 

determined, as well as the source of the donation. 

F. Contractual 

Report the cost of rent, utilities, and other contracted items or 

services that were used in operating an LITC program. Donated 

space may be included as matching funds and the value 

assigned may not exceed the fair rental value of comparable 

space. The explanation should identify: 

• Nature of the expense; 

• Whether the associated costs were paid using federal or 

matching funds; and 

• The source of the matching funds. 

If a contracted item or service pertains to other programs in 

addition to LITC activities, only the portion directly attributable to 

LITC activities may be allocated to the LITC program. The 

narrative must explain the methodology used to apportion costs 

between the LITC activities and other programs. 

There are two acceptable methodologies for calculating federal 

funds allocable to indirect costs: 

• Indirect Cost Rate Agreement 

i. Must be approved in advance; 

ii. Agreement must set forth cost items included in the 

rate; and 

iii. The clinic may not charge items included in the rate 

as separate expense items. 

• De Minimis 10 percent rate 

i. Rules are set forth in 2 CFR Part 200; and 

ii. Clinics that elect to use the de minimis rate are prohibited 

from charging administrative or facility costs as separate 

expense items. 

For example, if a clinic is part of a larger organization that has an 

indirect cost rate agreement and the rental cost of the facility in 

which the clinic operates is included in the negotiated rate, then 

the clinic may not include the facilities cost under the Contractual 

Expense category. Similarly, if the clinic elects to use the de 

minimis rate to charge indirect costs on all its federal awards, no 

facilities and administration costs may be charged as direct costs. 

G. Construction 

This category is not applicable to this grant. No construction 

expenses are allowed. 

H. Other Expenses 

Report all other direct costs that were incurred in operating an 

LITC program that are not properly included in categories A 

through G. The value of volunteer in-kind services is included in 

this category as matching funds.The explanation should identify: 

• Nature of the expense; 

• Whether the associated costs were paid using federal or 

matching funds; and 

• The source of the matching funds. 

The explanation must also disclose the rate or rates that were 

used to value volunteer in-kind services and the number of 

volunteer hours that were provided, categorized by type of 

service or volunteer, as appropriate. 

I. Total Direct Charges 

The total of the direct charges is the sum of lines A through H for 

each column. 

J. Indirect Charges 

Report indirect costs not directly related to the LITC program, but 

incurred as part of the general overhead and administration of the 

grantee. Indirect charges may be charged as a use of federal 

funds based upon an approved Indirect Cost Rate Agreement or 

the 10% de minimis rate allowed under 2 CFR Part 200. 

However, indirect charges may not be counted as matching funds 

and the rate may only be applied to the base paid with federal 

funds. The narrative explanation should identify the indirect cost 

rate, the base to which the rate was applied, and the computation 

for the indirect charges amount. Briefly summarize the expenses 

included in the indirect cost rate agreement. 

If indirect costs were charged to the LITC grant, no items that are 

included in the indirect cost rate or the de minimis rate may be 

charged as direct expenses. For example, if a clinic is part of a 

larger organization that has an Indirect Cost Rate Agreement and 

the rental cost of the facility in which the clinic operates is 

included in the negotiated rate, then the clinic may not include the 

facilities cost under the Contractual Expense category. Similarly, 

if the clinic elects to use the de minimis rate to charge indirect 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 
166 LOW INCOME TAXPAYER CLINICS

 

 

Page 6

costs on all its federal awards, no facilities and administration 

costs may be charged as direct costs. See Publication 3319 or 2 

CFR Part 200 for guidance on indirect charges. 

Matching Funds 

This section addresses matching funds from sources other than 

the federal government. Complete this section by providing a 

narrative that includes an explanation of the sources and 

amounts of matching funds. The clinic must state explicitly that 

matching funds provided to the LITC program (1) were not used 

as matching funds for any other federal program and (2) were not 

funds received from any other federal grant unless specifically 

authorized by statute to be used as matching funds. 

• List amount of match by source; and 

• List total of all match funding. 

Returning Unused Grant Funds 

Complete this section by providing a statement as to whether the 

clinic will spend its entire LITC grant award by the end of the 

grant year. In the event the clinic anticipates that it will not spend 

its entire award, the clinic must contact the LITC Program Office 

immediately so the funds can be redistributed to other grantees. 

Complete this section for the Year-End Report if the amount of 

unused grant funds at the end of the grant year exceeds $500. 

Include the reason(s) why excess grant funds were not 

expended or made available for redistribution to other grantees 

and whether this was due to a one-time occurrence or an 

ongoing issue. 

Request Additional Grant Funds (This section applies to the 

Interim report only.) 

If you wish to request additional LITC grant funds for the current 

grant year (to be used before December 31), and your LITC 

grant award is less than $100,000, indicate the amount of 

additional funds requested, the expense category or categories 

where the funds will be spent, and the amount and source of 

matching funds that will be provided if the additional funding is 

awarded. 

The total funds requested for the grant year may not exceed 

$100,000. See IRC § 7526(c)(2). After entering amounts into the 

Grant Expenditures Narrative, verify that the sum of the amounts 

listed under each expense type and each category (federal/ 

match) are consistent with the amounts listed on the Detailed 

Budget Worksheet. 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 
LOW INCOME TAXPAYER CLINICS 167 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Form 13424-L

(May 2018) 

Department of the Treasury - Internal Revenue Service 

Statement of Grant Expenditures 

OMB Number 

1545-1648 

Name of Low Income Taxpayer Clinic 

ABC LITC 

Grant Period 

From 1/1/2019 To 12/31/2019

Expense Categories Federal Match Total

A. Personnel 79,821 36,720 116,541

B. Fringe Benefits 1,525 21,783 23,308

C. Travel 2,079 2,079

D. Equipment

E. Supplies 1,900 1,900

F. Contractual 11,899 11,899

G. Construction

H. Other Expenses 28,263 28,263

I. Total Direct Charges 81,346 100,034 181,380

J. Indirect Charges 17,481 11,654

K. Totals 93,000 100,034 193,034

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 

For Paperwork Reduction Act Notice, see Publication 3319. 
LOW INCOME TAXPAYER CLINICS

Page 2

Grant Expenditures Narrative Explanations
­

A. Personnel 

ABC Legal Services computes 1.0 FTE on a 40-hour work week (2,080 hours per year) All dollars are rounded to the nearest dollar. FTE rounded to 

nearest hundreth. 

CD/QTE (Atty)-John Fordham-.8 FTE Annual Salary $89,000 x 0.8=$71,200 Federal:$50,000 Match: $21,200 (ABC Operating Funds, Legal 

Services Corporation, LSC) 

Paralegal- Alice Gonzaga .43 FTE $22 x 900 hours= $19,800 Federal: $10,000 $9,800 XYZ Private Foundation funds 

Intake- Ruth Washington .50 FTE $15 x 1036.09 hours= $15,541 Federal: $15,541 Match: $0 

Receptionist- Deborah Chapman 1/3 FTE x $30,000= $10,000 Federal: $4,280 Match:$5,720 XYZ Private Foundation funds 

Federal: $79,821 Match: $36,720 ($21,200 ABC Operating Funds/LSC + $15,520 XYZ Private Foundation) 

B. Fringe Benefits

Fringe Benefits are 20% of wages of $116,541. 

Federal:$1,525 Match: $21,783 XYZ Private Foundation funds.
­

C. Travel 

Local travel to conduct educational and outreach activities. $45 parking. $281 mileage (525 miles at $.535 per mile). 

$1,753 of travel to LITC Conference. $950 Hotel. $553 Air fare. $200 MI&E. Travel to and from airport $50 Taxi. 

Federal: $0 Match: $2,079 ($45 + $281 + $1,753) XYZ Private Foundation funds. 

D. Equipment

$0

E. Supplies

ABC Legal Services uses a full-time equivalent (FTE) method to allocate certain direct shared expenses, including Supplies, Telephone and Internet, 

ABC Legal Services uses a full-time equivalent (FTE) method to allocate certain direct shared expenses, including Supplies, Telephone and Internet, 

and and 2 CFR § 200.501 Audit Cost. Under this method, the allocation percentage is determined by dividing the FTEs of employee time devoted to 

the LITC program by the total FTEs available in the ABC Legal Services organization. The LITC program staffing will be 2.06 FTEs (.80 FTE for 

John Fordham + .43 FTE for Alice Gonzaga + .50 FTE for Ruth Washington + .33 FTE for Debra Chapman = 2.06 FTEs). Total FTEs in the ABC 

LegalServices organization is 40 FTEs. The ratio of shared expenses is estimated at 5.15% (2.06/ 40). 

Total cost of supplies for the organization is estimated to be $36,900 and will include the cost of laptop computers, printers, copy paper, toner, pens, 

pencils, envelopes, postage, etc. $36,900 x 5.15% = $1,900. 

Federal: $0 Match: $1,900 XYZ Private Foundation funds.
­

F. Contractual 

Total telephone and internet shared cost is estimated to be $35,880.$35,880 x 5.15%(FTE allocation) = $1,848. The organization's total audit cost (a 

shared expense) is estimated to be $20,400. $20,400 x 5.15% (FTE allocation)= $1,051. Advertising costs – These costs will be incurred solely to 

publicize the LITC program. Planned advertising for LITC representation and education services are estimated to be $3,000. 

Rent – Facilities costs are generally included in the Indirect Cost Rate Agreement. However, the organization will be renting off-site space at 

Neighborhood Drop-in, a community based organization, solely to conduct weekly intake. The cost of the space is $500 per month. $500 x 12 mo = 

$6,000. 

Federal: $0 Match: $11, 899($1,848 + $1,051 + $3,000 + $6,000) XYZ Private Foundation funds.
­

G. Construction 

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 

168 
 

Page 3

H. Other Expenses

Representation services: $230/hr x 87 hrs = $20,010. Non-representation services:
	

Volunteer attorneys will contribute services including research, consultations, and review of educational materials. Valuation rate is the same as pay
	

rate for staff attorney John Fordham. ($42.79/hr + $8.56/hr fringe) = $51.35/hr x 95 hrs = $4,878.
	

A bilingual Enrolled Agent will provide services including ESL consultations and review of educational materials. Valuation rate is consistent with
	

those paid for similar work in the labor market and were determined using BLS information for the locality plus reasonable fringe. ($22.50/hr +
	

$4.50/hr fringe) = $27/hr x 75 hrs = $2,025.
	

Law students will represent taxpayers before the IRS pursuant to a special appearance authorization. Valuation rate is $18/hr which represents 35%
	

of the staff attorney's pay rate, including fringe. (Note: students are not permitted to use the $230/hr rate available to other qualified
	

representatives.)$18/hr x 75 hrs = $1,350. Federal: $0 Match: $28,263 ($20,010+$4,878+$2,025+$1,350) Third Party In-Kind
	

I. Total Direct Charges 

J. Indirect Costs 

$116,541 x 15% = $17,481 

Federal: $11,654 

(Please note for this example the MTDC only takes into consideration the direct salary costs for LITC staff $116,541. Additional items such as 

fringe benefits supplies and materials and travel directly attributable to the work of the grant could also be utilized in calculating the MTDC if it can 

be shown they are direct costs of performing work under the LITC grant. See Section IV.E. ii, Direct vs. Indirect Expenses, Publication 3319 LITC 

Grant Application and Guidelines.) 

Matching Funds 

Total matching funds will be $100,034 from the following sources: 

$53,181 cash from XYZ Private Foundation 

$21,200 cash from ABC Corp Operating Funds (LSC) 

$25,653 third party in-kind 

These funds were not used as matching funds for any other federal program. 

Unused Grant Funds 

NA

Additional Funding Request (Interim Report ONLY) 

NA

Catalog Number 58506B www.irs.gov Form 13424-L (Rev. 5-2018) 

LOW INCOME TAXPAYER CLINICS 169 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX
170 LOW INCOME TAXPAYER CLINICS

INSTRUCTIONS FOR FORM 13424-N, LITC PROGRAM NARRATIVE 

REPORT 

Form 13424-N, LITC Program Narrative Report, is used to report information about certain representation, 

education, and advocacy work the clinic performed during the reporting period. This form is used to report 

narrative explanations of the program plan, how the clinic meets the requirements of the grant, trends in the 

types of cases encountered, and success stories of note that occurred during the reporting period. This form 

also provides an opportunity to supplement responses from other reporting forms included in the Interim and 

Year-end Report that relate to representation, education, and advocacy efforts. 

This form is also used to report the steps taken to resolve open cases and provide ongoing representation, where 

appropriate, for clinics that will no longer be participating in the LITC grant program in the next grant period. 

The Program Office uses the information reported on this form and the other reporting forms to determine 

the scope of services provided by clinics. Data from all clinics is totaled to provide program-wide statistical 

information about services provided to low-income and ESL taxpayers. 

Specific Instructions for Completing the Form 

All fields require an entry even if the response is N/A or Not Applicable. Each section has an 8,000 character 

limit, except where designated. For purposes of reporting on Program Plan Progress (Section 1) and addressing 

Grant Requirements (Section 2), clinics should report activities performed between January 1 and June 30 on the 

Interim Report. The Year-end Report will cover work performed between January 1 and December 31 with the 

exception of Success Stories (Section 3) and Emerging Issues (Section 4), which should be answered from work 

performed during the second half of the year only. However, if an emerging issue was included in the Interim 

Report, and continued through the second half of the year, it is appropriate to include it again in the Year-end 

Report, especially if the issue or trend increased in prevalence or new examples of it were identified. To the extent 

that these instructions may conflict with the information included with the Form 13424-N fillable form, please 

follow the instructions provided here. 

Program Plan Progress 

The system will navigate to the screen below when the Form 13424-N is selected on the Form Selection screen. 

Report the progress made in implementing the program plan during the reporting period in this section. 

Include the description of the progress made in meeting the numerical and substantive goals and objectives, 

respectively, that were detailed in the grant application on Form 13424-M, Low Income Taxpayer Clinic 

Application Narrative, or as revised in any amendments or continuing funding requests. 
LOW INCOME TAXPAYER CLINICS 171 

APPENDIX B

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V VI APPENDIX B GLOSSARY INDEX

Grant Requirements 

In this section, report how certain requirements of the LITC grant were met. 

Use line 2.ix to supplement responses from other reporting forms included in the Interim and Year-end Report 

that relate to representation, education, and advocacy efforts. 
172 LOW INCOME TAXPAYER CLINICS

Emerging Issues 

Report frequently encountered trends identified in the types of cases encountered through work on behalf of lowincome or ESL taxpayers during the reporting period in this section. 

Input one issue per item box. Click on the Add button to enable the additional line option. 

NOTE: Do not include any confidential or personally identifiable taxpayer information. See Publication 3319 for 

additional information about confidentiality. 

Success Stories 

Report notable stories of achievement of the LITC mission that occurred during the reporting period in this 

section. 

Input one issue per item box. Click on the Add button to enable the additional line option. 

The response should describe particular cases or activities but do not include any confidential or personally 

identifiable taxpayer information. See Publication 3319 for additional information about confidentiality. 

Last Year in LITC Program 

Only complete this section if included with a final Year-end report of a clinic that will not be receiving LITC 

grant funding in the next grant period. 

If the clinic will no longer be participating in the LITC grant program, report the steps taken to resolve open cases 

and provide ongoing representation, where appropriate. 

To finalize the form, see the instructions for how to save, validate, and submit forms. 
LOW INCOME TAXPAYER CLINICS 173 

APPENDIX B

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V VI APPENDIX B GLOSSARY INDEX

HOW TO SAVE, VALIDATE, AND SUBMIT FORM 13424 SERIES 

Click Save to save data entered before validating. When ready to submit the form, click Validate to indicate the 

information is complete. 

When there are errors, the system will refresh to the screen below and list at the top of the screen the fields that 

were not completed. The system will not allow the report status to change to Validated until all issues are resolved 

and the form is re-validated. 

The system will refresh to the screen below and the report status will show as Validated if there are no errors and 

once all errors are corrected. 

Once a reporting form is saved and validated without any errors, it is ready to be submitted to the LITC Program 

Office. The statuses can be found on the Form Selection screen and/or within each form itself. The individual who 

has the role of Principal Investigator/Program Director (PI/PD) must submit the reporting forms. Ordinarily, this 

is the Clinic Director; in some organizations, this role may be held by the Executive Director. 

To submit reporting forms, do the following: 

n	Go to the Form Selection screen; 

n	Locate the form to submit; 

n	Follow the steps above to access the form; and 

n	Click on the Submit link. (The submit link will not appear until the form moves to the Validated status). 
174 LOW INCOME TAXPAYER CLINICS

NOTE: Once a form is submitted to the Program Office it is no longer editable. To edit a form that was 

prematurely submitted, email the LITC Program Office at LITCProgramoffice@irs.gov and copy the clinic’s 

assigned advocacy analyst. The advocacy analyst will contact the organization to confirm the request and the form 

will be returned for edit. Follow the instructions above to resubmit the form to the LITC Program Office. 

To exit the form, click the Form Selection link and the system will navigate back to the form details screen. 
LOW INCOME TAXPAYER CLINICS 175 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

 

INSTRUCTIONS FOR STANDARD FORM 425, FEDERAL FINANCIAL 

REPORT (YEAR-END ONLY) 

Standard Form 425, Federal Financial Report, is used to report the amount of federal grant funds received and 

spent during the grant period and the amount of matching funds spent during the grant period. In preparing this 

form, adhere to existing guidelines in 2 CFR Part 200 and Publication 3319, which explain allowable costs. See 

Publication 3319, 2 CFR § 200.306, and 2 CFR § 1000.306 for guidance on matching funds. 

The instructions for completing Standard Form 425, Federal Financial Report, contained in this Publication 

are intended as a guide for submitting LITC grant reports. For instructions on preparing required quarterly 

submissions of the Cash Transactions Record in the Payment Management System (PMS), visit the PMS Program 

Support Center at https://pms.psc.gov/ and click on the Training tab. 

Accessing the Form 

To access Standard Form 425 on GrantSolutions, click on the Reports link on the My Grants List screen. 

The system will navigate to the screen below. Click on the drop-down arrow on the right-hand side for past 

reporting periods. Click on the start button or edit button. 

HINT: You may need to look under past reporting periods to find the correct period. 
176 LOW INCOME TAXPAYER CLINICS

Completing the Form 

The system will then navigate to the screen below. All fields on the form must be completed. 

Scroll down on this screen and the next section includes lines 1-9, which will be prepopulated and locked down 

from editing, except for line 7, Basis of Accounting. Please select either Cash or Accrual to indicate which basis 

was used for recording transactions related to the grant award and for preparing this Standard Form 425. See the 

Glossary for an explanation of each basis of accounting. 
LOW INCOME TAXPAYER CLINICS 177 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Continue to scroll down and the next section is lines 10(a) – 10(c). 

Line 10(a). Enter the amount of federal cash that the clinic has drawn down from the XXXX grant award in the 

PMS account. 

Line 10(b). Enter the amount of federal cash reported on line 10(a) that has been disbursed to pay or reimburse 

LITC expenses. 

NOTE: For lines 10(a) and 10(b) on the Year-end Report, these amounts should include any drawdowns or 

disbursements made after December 31, XXXX but before the date the report is submitted. 

Line 10(c). Enter the amount of line 10(a) minus line(b). The system will automatically calculate this amount. 

Next, scroll down further and the next section contains the federal expenditures and unobligated balances, lines 

10(d) – 10(h). 

Line 10(d). The amount of federal funds authorized is prepopulated and cannot be changed. 

Line 10(e). Enter the amount of federal funds expended during the grant period. See Glossary for an explanation 

of the cash and accrual bases of accounting. 

Line 10(f ). Enter the amount of federal funds that represent expenses incurred but not yet paid as of the end of 

the reporting period, if not reported on line 10(e). Cash basis reporters may need to enter an amount on this line; 

for accrual basis reporters, the amount on this line will likely be zero. 

Line 10(g). The system will automatically calculate the sum of lines 10(e) and 10(f). 

Line 10(h). The system will automatically calculate line 10(d) minus 10(g). On the Year-end Report, the amount 

shown on this line represents unspent grant funds and must be explained in the narrative on Form 13424-L, 

Statement of Grant Expenditures. 
178 LOW INCOME TAXPAYER CLINICS

Scroll down and the next section contains the recipient share, lines 10(i) – 10(k). 

Line 10(i). For the purposes of the LITC Program, the term “recipient share” has the same meaning as the term 

“matching funds.” Enter the amount of matching funds required for grant year XXXX. The amount should be the 

same as line 10(g) because the LITC grant requires a dollar-for-dollar match. 

Line 10(j). Enter the amount of matching funds expended during the reporting period specified on line 9, 

including the value of all third period in-kind contributions. 

NOTE: This can be more than the federal amount if more matching funds were received. This amount should be 

equal to the match amount claimed on Form 13424L. 

Line 10(k). The system will automatically calculate line 10(i) minus 10(j). 

Scroll down and the next section contains program income, lines 10(l) – 10(o). 

Line 10(l). Enter the amount of nominal fees or other program income earned during the reporting period. Do 

not report any program income here that is being allocated as part of the recipient’s match amount included in 

Line 10(j). 

Line 10(m). Enter zero. The LITC Program does not utilize the deduction alternative. 

Line 10(n). Enter the amount of program income that was added to funds committed to the total project costs 

and expended to further eligible project or program activities. 

Line 10(o). The system will automatically calculate line (l) minus line (m) or line (n). This amount equals the 

program income that has been earned but not expended, as of the reporting period end date. 

Scroll down to the section that contains indirect expenses, lines 11(a) – 11(g). 
LOW INCOME TAXPAYER CLINICS 179 

APPENDIX B

VII I II III IV

V VI APPENDIX B GLOSSARY INDEX

Enter cumulative amounts from date of the inception of the award through the end date of the reporting period 

specified on line 9. Only grant recipients using an indirect cost rate should complete this section. Otherwise, skip 

to line 12. 

Line 11(a). State whether the type of indirect cost rate is Provisional, Predetermined, Final, Fixed, or de minimis. 

NOTE: Although changes were made to 2 CFR 200 in April 2024, those changes may not be reflected on all the 

forms on the GrantSolutions system at the time that the year-end report is submitted. If the de minimis indirect 

cost rate populates incorrectly, please reach out to the LITC Program Office for assistance. 

Line 11(b). Enter the indirect cost rate in effect during the reporting period. 

Line 11(c). Enter the beginning and ending effective date dates for the rate. 

Line 11(d). Enter the amount of the base against which the rate(s) was applied. 

Line 11(e). Enter the amount of indirect costs charged during the time period specified. (Multiply 11(b) by 11(d)). 

Line 11(f). Enter the amount of grant funds awarded for the reporting period that were allocated to indirect costs. 

Scroll down and the next section contains a place for comments. There should not be any attachments to the 

Standard Form 425. 
180 LOW INCOME TAXPAYER CLINICS

Submitting the Standard Form 425 

Scroll down and the next section is line 13, the certification and submission. First, click on check for errors. The 

system does a validation of the information within the form. (It does not validate against information in other 

report forms.) If there are no errors, a pop-up box will appear and say, no errors found. If there are errors, the 

pop-up box will appear with a list of the errors to be addressed. 

When the form is ready to be submitted, put a check mark in the box under line 13, next to the certification 

statement. Once the box is checked, the submit report button will turn blue, indicating it is enabled. 

NOTE: The submit report button will not be enabled if there are any errors on the form. 
LOW INCOME TAXPAYER CLINICS 181 

VII APPENDICES I II III IV

V VI FEDERAL GRANT ACRONYMS

FEDERAL GRANT ACRONYMS
182 LOW INCOME TAXPAYER CLINICS

ABA American Bar Association 

ACS Automated Collection System 

BLS Bureau of Labor Statistics 

CFR Code of Federal Regulations 

CLE Continuing Legal Education 

CPA Certified Public Accountant 

CPE Continuing Professional Education 

CRU Civil Rights Unit 

DoD Department of Defense 

DUNS Data Universal Numbering System 

EA Enrolled Agent 

EDI Equity, Diversity, and Inclusion 

EFT Electronic Funds Transfer 

EIN Employer Identification Number 

EITC Earned Income Tax Credit 

ESL English as a Second Language 

F&A Facilities and Administrative Costs 

FAC Federal Audit Clearinghouse 

FDIC Federal Deposit Insurance Corporation 

FFATA Federal Funding Accountability and Transparency Act 

FOIA Freedom of Information Act 

FTE Full-time equivalent 

GAAP Generally Accepted Accounting Principles 

GSA General Services Administration 

HHS Department of Health and Human Services 

ICRA Indirect Cost Rate Agreement 

IHE Institutions of Higher Education 

IRB Internal Revenue Bulletin 

IRC Internal Revenue Code 

ITIN Individual Taxpayer Identification Number 

LEP Limited English Proficiency 

LITC Low Income Taxpayer Clinic 

LSC Legal Services Corporation 

LTA Local Taxpayer Advocate 

MCLE Mandatory or Minimum Continuing Legal Education 
LOW INCOME TAXPAYER CLINICS 183 

FEDERAL GRANT ACRONYMS

VII APPENDICES I II III IV

V VI FEDERAL GRANT ACRONYMS

MIE Meals and Incidental Expenses 

MTDC Modified Total Direct Costs 

NCC Non-Competing Continuation 

NOA Notice of Award 

NTA National Taxpayer Advocate 

OIC Offer in Compromise 

OMB Office of Management and Budget 

PMS Payment Management System 

PSA Public Service Announcement 

QBA Qualified Business Administrator 

QTE Qualified Tax Expert 

SAM System for Award Management 

SAMS Systemic Advocacy Management System 

SSN Social Security Number 

TAC Taxpayer Assistance Center 

TAS Taxpayer Advocate Service 

TBOR Taxpayer Bill of Rights 

TCE Tax Counseling for the Elderly 

TCO Tax Compliance Officer 

TIN Taxpayer Identification Number 

TVPA Trafficking Victims Protection Act of 2000 

UEI Unique Entity Identifier 

VITA Volunteer Income Tax Assistance 

NOTE: For additional helpful IRS and tax-related acronyms, see the Glossary of Acronyms from the most 

recent National Taxpayer Advocate Annual Report to Congress. 
184 LOW INCOME TAXPAYER CLINICS

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LOW INCOME TAXPAYER CLINICS 185 

VII APPENDICES I II III IV

V VI GLOSSARY

GLOSSARY
 
186 LOW INCOME TAXPAYER CLINICS

90/250 Income Requirement – at least 90 percent of taxpayers represented by an LITC must have incomes 

which do not exceed 250 percent of the poverty level or criteria established by the Director of the Office of 

Management and Budget (OMB). See IRC § 7526(b)(1)(B)(i). The Director of OMB has not established a 

poverty level or criteria. The Department of Health and Human Services (HHS) publishes annual Federal Poverty 

Guidelines based on family unit size and geographic location, which are applicable to the LITC Program. For 

2024, the Federal Poverty Guidelines were published at 89 Fed. Reg. 2961-2963 (Jan.17, 2024). 

A

Allowable Expenses – expenses chargeable to a grant as a use of federal funds or matching funds in accordance 

with the cost principles guidance in 2 CFR Part 200 and 2 CFR Part 1000. Generally, for an expense to be 

allowable, the expense must: 

n	 Be necessary and reasonable for the performance of the federal award and be allocable thereto under the 

applicable cost principles; 

n	 Conform with any limitations or exclusions set forth in the cost principles or in the Notice of Award; 

n	 Be consistent with policies and procedures that apply uniformly to both federally-financed and other 

activities of the grant recipient; 

n	 Be accorded consistent treatment by the grant recipient; 

n	 Be determined in accordance with generally accepted accounting principles (GAAP), except for state 

and local governments and Indian tribes only, as otherwise provided for in the cost principles; 

n	 Not be included as a cost or used to meet cost sharing or matching requirements of any other federallyfinanced program in either the current or a prior period; 

n	 Be adequately documented; and 

n	 Be incurred during the approved budget period. However, the federal awarding agency is authorized, 

at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent 

budget periods pursuant to 2 CFR § 200.308(g)(3). 

Application – a request for LITC grant funding submitted to the LITC Program Office. When used it is referring 

to either an LITC Full Grant Application or a Non-Competing Continuation (NCC) Request, depending upon 

the type of application that the organization needs to complete. 

Appropriation – a law authorizing federal agencies to obligate funds and make payments from the U.S. 

Department of the Treasury for specified purposes. Appropriations are annual acts and permanent law. Until 

Congress makes an appropriation for the LITC Program, the LITC Program Office may not be able to inform 

grant recipients of the amount of their funding. 

Award – the provision of funds by the LITC Program Office to an organization to carry out activities in support 

of the LITC mission. It is based on an approved application and budget and is subject to a federal appropriation. 
LOW INCOME TAXPAYER CLINICS 187 

GLOSSARY

VII APPENDICES I II III IV

V VI GLOSSARY

C 

B 

Basis of Accounting – the time at which financial transactions are recorded. There are two primary methods for 

tracking income and expenses. With accrual basis accounting, income is recorded when earned and expenses are 

recorded when incurred. With cash basis accounting, income is recorded when received and expenses are recorded 

when paid. 

Budget – a request for funds to support an activity, presented by expense category. An initial budget is submitted 

with the application proposing how the applicant intends to use the funds. If an award is made, the clinic will 

submit a revised budget with the clinic’s application amendment that is due shortly after the award amount is 

finalized and the Notice of Award is issued. 

Case Management System – a system that may be used by grant recipients to capture intake information, 

calculate client financial eligibility, track case status and outcomes, input case notes, maintain timekeeping 

records, record educational and outreach activities, and compile data for Interim and Year-end Reports. LITCs 

are strongly encouraged to use case management software to maintain and monitor client files. An LITC may 

purchase case management software with grant funds to efficiently track and report its program activities. 

Catalog of Federal Domestic Assistance (CFDA) – a governmentwide compendium of federal programs and 

activities that provide assistance or benefits. See https://sam.gov/content/assistance-listings. The CFDA number 

for the LITC Program is 21.008. 

Clinic Director – a staff member who has overall management responsibility for the clinic. The Clinic Director 

may also be the QTE or QBA, if qualified. The Clinic Director manages day-to-day clinic operations, prepares or 

reviews the required clinic reports, and signs reports as the clinic’s authorized representative. The Clinic Director 

serves as the primary contact person for both the LITC Program Office and the Local Taxpayer Advocate (LTA) 

office. In most circumstances, the Clinic Director will have the role of Principal Investigator/Program Director 

(PI/PD) in GrantSolutions for purposes of signing and submitting forms. In some organizations, the PI/PD may 

be the Executive Director. 

Closeout – the process by which the federal awarding agency determines that all applicable administrative 

actions and all required work of the federal award have been completed and takes actions as described in 

2 CFR § 200.344. 

Congressional District – an electoral constituency, apportioned by population, which elects a Member of Congress. 

Continuing Legal Education (CLE) – an accredited professional educational program for attorneys. CLE is 

also known as MCLE (Mandatory or Minimum Continuing Legal Education). The number of CLE credit hours 

will vary by program and is dependent upon state CLE board approval. CLE rules vary by jurisdiction. Some 

jurisdictions may not allow CLE credit for all types of programs, such as teleconferences or webinars. 
188 LOW INCOME TAXPAYER CLINICS

Continuing Professional Education (CPE) – an accredited educational program required to maintain a 

professional license, such as a Certified Public Accountant or Enrolled Agent designation. 

D 

Demographics – vital or social statistics (e.g., income, education level, native spoken language) of a group or 

population of taxpayers within a defined state, county, or geographic regional area. 

Digital Accountability and Transparency Act of 2014 (The Data Act) – a law that requires the U.S. 

Department of the Treasury to establish common standards for financial data provided by all government agencies 

on the USASpending website to increase transparency in federal expenditures and to make the information more 

accessible to the public. Among other objectives, the Data Act also aims to simplify reporting for entities receiving 

federal funds and improve the quality of submitted data. 

Direct Costs – costs that can be identified with or allocated specifically to a particular program, such as an LITC 

Program, with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be 

treated consistently as either direct or indirect. For additional information, see 2 CFR § 200.413. 

Direct Lobbying – activities supporting the enactment, modification, or adoption of any law, regulation, or 

policy at any level of government. Direct lobbying includes influencing or attempting to influence a Member of 

Congress, a state or local legislator, or any of their staff members to take a position or action on a specific piece of 

legislation or potential legislation. For additional information, see 2 CFR § 200.450. 

E 

Engagement Letter – an agreement that defines the specific matters for which the LITC will provide 

representation and protects both the representative and the taxpayer by informing both parties as to the agreement 

of assigned responsibilities over the course of the professional relationship. Written copies of the engagement letter 

or retainer agreement signed by both the representative and the taxpayer should be retained by the LITC and a 

copy should be retained by the taxpayer. 

F 

Family Unit – for purposes of the 90/250 rule, a family unit is generally defined as an unrelated individual or a 

family. An unrelated individual is a person 15 years old or over not living with persons related by birth, marriage, 

or adoption. A family is a group of two or more persons related by birth, marriage, civil union, or adoption who 

live together. However, if related individuals live together, but the person seeking assistance from the LITC is 

financially independent, then that person may be treated as a family unit, distinct from relatives in the household. 

If two unrelated individuals live together, they constitute two family units. 

Federal Register – an official daily publication that provides a uniform system for communicating proposed and 

final regulations and legal notices issued by federal agencies, including announcements of the availability of funds 

for financial assistance programs. 
LOW INCOME TAXPAYER CLINICS 189 

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VII APPENDICES I II III IV

V VI GLOSSARY

Fringe Benefits – allowances and services provided by employers to their employees as compensation in addition 

to regular salaries and wages. Fringe benefits include, but are not limited to, the costs of leave (vacation, familyrelated, sick, or military), employee insurance, pensions, and unemployment benefit plans. For additional 

information, see 2 CFR § 200.431. 

G 

Grant – a financial assistance mechanism providing money, property, or both to an eligible entity to carry out an 

approved project or activity. 

I 

Indirect Costs – costs that have been incurred for common or joint objectives with other grant programs and 

cannot be readily identified with the LITC Program. After direct costs have been determined and assigned directly 

where appropriate, indirect costs are those remaining to be allocated to a particular program. Direct cost of minor 

amounts may be treated as indirect costs under the conditions described in 2 CFR § 200.413(d). A cost may 

not be allocated to the LITC Program as an indirect cost if any other cost incurred for the same purpose, in like 

circumstances, has been assigned to another federal award as a direct cost. Indirect costs may be charged as a use of 

federal funds based upon an approved Indirect Cost Rate Agreement or the de minimis rate of 15 percent allowed 

under 2 CFR § 200.414. Indirect costs are not allowable as matching funds. 

Intake – a process used by clinic staff to gather information from a taxpayer seeking assistance to determine 

eligibility for services. LITCs must record the taxpayer’s income information on an intake form (paper or 

electronic). If the taxpayer is part of a family unit, the income of the family unit should be reported and utilized in 

the eligibility determination. LITCs must also determine and document the amount in controversy during intake. 

Individual Taxpayer Identification Number (ITIN) – a unique nine-digit number used for tax administration 

purposes that the IRS issues to individuals who are not eligible to obtain a Social Security number (SSN). 

L 

Local Taxpayer Advocate (LTA) – a delegate of the National Taxpayer Advocate (NTA) who is a manager in a 

local jurisdiction and reports to the NTA. IRC § 7803(c)(2)(D)(i)(I) requires that each state have at least one LTA 

who is independent of the local IRS office. Each LTA provides essential guidance and assistance to the LITCs 

within his or her geographic area or as assigned by the LTA’s manager. 

Limited Entry of Appearance – to improve efficiency and to encourage the assistance of unrepresented taxpayers, 

the U.S. Tax Court has allowed practitioners to enter Limited Entry of Appearance. See Tax Court Rule 24, 

limited representation means that the legal services provided are limited in scope and duration to less than full 

representation. 
190 LOW INCOME TAXPAYER CLINICS

M 

Matching Funds – the portion of program costs not funded by federal funds. Grant recipients must 

provide matching funds on a dollar-for-dollar basis for all LITC grant funds received. See IRC § 7526(c)(5), 

2 CFR § 200.1, and § 200.306 for more information. Only funds that are used in direct support of the LITC 

Program qualify as matching funds. Uniform Administrative Requirements, Cost Principles, and Audit Requirements 

for Federal Awards, 2 CFR § 200.306 (and the U.S. Department of the Treasury’s implementation thereof at 

2 CFR § 1000.306) provides that all contributions, including cash and third-party in-kind, shall be accepted as 

part of the grant recipient’s cost sharing or matching when such contributions: 

n	 Are verifiable from the grant recipient’s records; 

n	 Are not included as contributions for any other federally assisted project or program; 

n	 Are necessary and reasonable for proper and efficient accomplishment of project or program objectives; 

n	 Are allowable under the applicable cost principles; 

n	 Are not paid by the federal government under another award, except where authorized by the federal 

statute to be used for cost sharing or matching; 

n	 Are provided for in the approved budget when required by the federal awarding agency; and 

n	 Conform to other provisions of 2 CFR Part 200, when applicable. 

N 

National Taxpayer Advocate (NTA) – the official who supervises and directs the Office of the Taxpayer Advocate. 

The NTA reports directly to the IRS Commissioner and serves as the voice of the taxpayer with the IRS and 

before Congress. Final LITC grant funding decisions are made by the NTA, unless recused. In recusal situations, 

final funding decisions are made by the Deputy National Taxpayer Advocate. 

Non-Competing Continuation (NCC) Request – a request for LITC grant funding submitted to the LITC 

Program Office through GrantSolutions and using the specified forms in accordance with LITC Program Office 

instructions. NCC Requests must be submitted in lieu of a Full Grant Application by organizations already 

funded with a multiyear LITC grant. 

O 

Office of Management and Budget (OMB) – the White House office that oversees the preparation of the federal 

budget and supervises its administration in Executive Branch agencies. OMB evaluates the effectiveness of agency 

programs, policies, and procedures, assesses competing funding demands among agencies, and sets funding 

priorities. OMB ensures that agency reports, rules, testimony, and proposed legislation are consistent with the 

President’s Budget and with Administration policies. 

OMB Guidance – comprehensive principles issued by OMB that provide guidance relating to the administration 

of federal grant awards. Grant award administrative requirements are set forth in the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200 (and U.S. Department 
LOW INCOME TAXPAYER CLINICS 191 

GLOSSARY

VII APPENDICES I II III IV

V VI GLOSSARY

of the Treasury has implemented those requirements at 2 CFR Part 1000). The Uniform Guidance helps ensure 

the highest integrity in the financial management and operation of federal grant programs and strengthens 

accountability for federal funds by improving policies that protect against waste, fraud, and abuse. In addition, the 

guidance aims to minimize the time applicants and grant recipients must spend complying with administrative 

requirements. 

Operational Review Visit – a site assistance visit conducted by LITC Program Office staff to evaluate a clinic’s 

overall operations and to provide technical assistance to help the grant recipient maintain compliance with the 

terms and conditions of the LITC grant. During an operational review visit, an LITC Advocacy Analyst will 

interview clinic personnel, examine intake procedures, review case management and reporting systems, and 

sample financial records. An operational review visit may also include observation of clinic facilities and review 

of procedures and internal controls, personnel policies, training plans, privacy and confidentiality policies, 

outreach plans and materials, educational curricula, fee policies, and client satisfaction instruments. When 

monitoring and evaluating clinic activities, the LITC Program Office will respect the clinic’s duty to protect 

confidential information and will not interfere with the confidential nature of the relationship between qualified 

representatives and their clients. The LITC Program Office strives to conduct an operational review visit to each 

clinic at least once every three years. However, the LITC Program Office may conduct an operational review visit 

at any time. 

Orientation Visit – a site assistance visit conducted by LITC Program Office staff to a grant recipient that did not 

receive a grant in the previous year. An orientation visit generally occurs during the first 120 days of the grant year. 

An orientation visit provides an opportunity to familiarize a new grant recipient with LITC Program requirements 

and to measure the progress of its start-up activities. Specifically, an orientation visit allows the LITC Program 

Office to assess the status of newly funded clinics and to identify potential areas where the grant recipient may 

need to create systems or improve processes to meet the requirements of the LITC Program. 

P 

Payment Management System (PMS) – an electronic system maintained by the Department of Health and 

Human Services that is used to pay federal funds. New grant recipients must create an account with PMS and 

obtain a username and password to use the system. PMS allows a grant recipient to make an online request for 

payment of federal funds. After a request is processed and approved, funds are directly deposited into the grant 

recipient’s bank account through a process called Electronic Funds Transfer (EFT). Funds are generally available 

within one business day of the request. PMS is also utilized by grant recipients to submit required Federal Cash 

Transaction Reports. Failure to timely submit the required reports may lead to PMS freezing access to grant funds. 

Q 

Qualified Business Administrator (QBA) – a staff member with sufficient business administration expertise 

to oversee the clinic’s business operations. The QBA must demonstrate education or experience with business 

or program administration, such as internal controls, grant funds management, budgeting, procurement, or the 

equivalent. If a department, as opposed to a single individual, fulfills this requirement, please provide details in the 

grant application about the staff member who oversees the department. 
192 LOW INCOME TAXPAYER CLINICS

Qualified Tax Expert (QTE) – generally, a staff member of the clinic (or a volunteer in the case of the ESL 

Education Pilot Program) with sufficient tax law expertise to oversee technical substantive and procedural tax 

matters. The QTE must be a qualified representative. The QTE is also responsible for reviewing all educational 

materials for accuracy before distribution. 

R 

Representation – acting as an agent of the taxpayer in an advocacy capacity in a matter before the IRS, the U.S. 

Tax Court, or another federal court, or before a state or local tax authority when the clinic is representing the 

taxpayer in a related federal tax controversy. Fact finding or advice alone does not constitute representation. 

S 

Special Appearance Authorization – a letter issued by the Director of the LITC Program Office that authorizes 

students and law graduates working at an LITC or Student Tax Clinic Program to represent taxpayers before the 

IRS. Practice under a special appearance authorization is limited to students and law graduates at an LITC or 

Student Tax Clinic Program working under the direct supervision of an individual authorized to practice before 

the IRS. For additional information, see Section VI.C.xii, Representing Low-Income Taxpayers. 

Standards of Operation – baseline operational requirements developed by the LITC Program Office and 

applicable to all clinics to ensure that all programs provide consistent and quality service to low-income and 

English as a second language (ESL) taxpayers. 

Support Staff – a group of people within an organization who perform such activities as answering the phone, 

scheduling appointments, copying materials, maintaining information on employees or volunteers, and 

maintaining timekeeping records. 

Systemic Advocacy – identifying and advocating for issues that impact low-income and ESL taxpayers utilizing a 

variety of methods, including but not limited to: 

n	 Participating in advocacy projects with professional organizations; 

n	 Commenting on proposed IRS regulations and guidance; 

n	 Preparing and filing an amicus brief to alert a court about the concerns of low-income or ESL taxpayers; 

n	 Authoring articles in scholarly journals or general interest publications; 

n	 Appearing on television or radio to raise awareness about tax issues that affect low-income or ESL 

taxpayers; 

n	 Producing public service announcements; or 

n	 Submitting issues to the Systemic Advocacy Management System (SAMS), available through the IRS 

website at www.irs.gov/advocate/systemic-advocacy-management-system-sams. 
LOW INCOME TAXPAYER CLINICS 193 

GLOSSARY

VII APPENDICES I II III IV

V VI GLOSSARY

T 

Tax Compliance Officer (TCO) – an authorized individual responsible for handling the organization’s federal 

tax matters and with whom the LITC Program Office can address any issues identified during federal tax 

compliance reviews of applicants and grant recipients. If the applicant is part of a larger organization (e.g., 

academic institution which operates a clinic), the LITC Program Office must be able to verify that the sponsoring 

organization does not have a federal tax compliance issue before awarding grant funds. Applicants must also 

provide documentation (e.g., articles of incorporation or a Form 2848) that shows the individual identified as 

the TCO on Form 13424 is properly authorized to receive tax information to prevent the IRS from making an 

unauthorized disclosure. 

Tax Counseling for the Elderly (TCE) – an IRS initiative designed to promote and support free tax counseling 

and basic income tax return preparation for individuals aged 60 years or over who cannot afford professional 

assistance. Cooperative grant agreements are entered into between the IRS and eligible organizations to provide 

the free tax return preparation assistance. 

Tax Return Preparation – an LITC can provide assistance with a federal tax return, a claim for refund, or an 

ITIN application if such assistance is necessary to resolve a controversy with the IRS or limited preparation may 

be done when ancillary to an LITC’s ESL education program. 

Technical Assistance Consultation – a discussion with a practitioner or other service provider designed to give 

brief advice about a tax issue. 

Third Party In-Kind Contributions – the value of non-cash contributions provided as matching funds by parties 

other than the grant recipient or federal government. Third party in-kind contributions may be in the form of 

goods, office space, or services donated to the LITC. 

U 

Unallowable Expenses – expenses for which LITC grant funds may not be used according to restrictions 

published by OMB, the LITC Program Office, appropriations language, or conditions outlined in the grant 

recipient’s Notice of Award. 

Underserved Area – an identifiable geographic area where the need for LITC services exceeds the capacity 

available from current grant recipients. 

Unique Entity Identifier (UEI) – the official identifier for doing business with the government and is assigned 

and managed through the System for Award Management (SAM.gov). The UEI replaced the Data Universal 

Numbering System (DUNS) number. 

Unused Funds – the portion of grant funds awarded to clinics that has not been spent, whether or not those 

funds have been drawn down from PMS. If a grant recipient determines that it will not spend its entire award, the 

grant recipient should immediately notify the LITC Program Office. 
194 LOW INCOME TAXPAYER CLINICS

V 

Volunteer Income Tax Assistance (VITA) – an IRS initiative designed to promote and support free tax return 

preparation service for the underserved through various community partner organizations. This service helps 

low- to moderate-income individuals, persons with disabilities, the elderly, and limited English speakers file their 

tax return each year. The IRS awards matching funds to these support organizations that offer free tax return 

preparation services during the tax filing season at locations in all 50 states and the District of Columbia. 
LOW INCOME TAXPAYER CLINICS 195 

VII APPENDICES I II III IV

V VI INDEX

INDEX
196 LOW INCOME TAXPAYER CLINICS

Numbers

90/250 requirement/rule 5, 39, 51, 52, 53, 54, 55, 85, 

88, 186, 188

A

advertising 23, 43, 63

advocacy, defined 5

allowable expenses 22, 71, 186

amicus brief 6, 63, 192

amount in controversy 4, 6, 39, 50, 55, 56, 57, 152, 

189

eligibility/limit 50, 55, 57, 85

interest on 56

application amendment 76, 77, 187

appropriation, defined 186

appropriation(s) 4, 34, 37, 72, 74, 186

attorneys’ fees 47, 48

audit

audited financial statement(s) 17, 18, 19, 94, 95

audit reconsideration 151, 152

cost of 31

Federal Audit Clearinghouse 17, 18, 94, 95, 124, 

125, 126

in educational activities 124

in the Uniform Guidance 30

PMS information for 71

single audit 17, 18, 94, 95, 124, 125, 126

B

budget 7, 21, 26, 27, 34, 38, 41, 71, 76, 78, 81, 84, 

94, 95, 108, 131, 155, 186, 187, 190, 191

C

case management system 48, 187

cases, defined 6

Catalog of Federal Domestic Assistance (CFDA) 

Number 91, 99, 187

changes in

entity or sponsoring organization 77

key personnel 78

organization name 20

program plan or budget 7, 18, 76, 78, 95, 124, 

125

taxpayer’s financial status 55

civil rights protection 69, 87, 125

civil rights review 18, 95, 117, 124, 125

clinic, defined 6

Clinic Director 7, 37, 38, 39, 41, 61, 78, 104, 113, 

128, 173, 187

closeout 9, 81, 187

conference 41, 84, 157

See also LITC Grantee Conference

confidentiality 44, 45, 94, 128, 172, 191

congressional district(s) 96, 100, 187

consultation(s) 6, 8, 18, 42, 44, 48, 50, 51, 54, 58, 76, 

85, 124, 133, 136, 137, 148, 153

Continuing Legal Education (CLE) 39, 62, 139, 187

Continuing Professional Education (CPE) 39, 62, 

139, 188

controversy, defined 6

controversy representation 11, 22, 29, 51, 61, 138

D

Data Universal Numbering System (DUNS) 20, 98, 

193

Digital Accountability and Transparency Act of 

2014 65, 188

direct costs 26, 111, 158, 159, 188

See also direct expenses

direct expenses 159

direct lobbying 72, 188

E

education 7, 8, 11, 13, 23, 32, 38, 39, 41, 42, 44, 61, 

62, 63, 64, 69, 73, 83, 85, 133, 137, 170, 171, 

188, 191

educational activities 7, 11, 18, 23, 43, 46, 61, 62, 76, 

124, 134, 136

eligibility screening 12, 32, 48

Employer Identification Number (EIN) 20, 97
LOW INCOME TAXPAYER CLINICS 197

INDEX

VII APPENDICES I II III IV

V VI INDEX

engagement letter 51, 188

English as a second language (ESL) 1, 5, 6, 7, 8, 11, 

13, 18, 32, 34, 35, 38, 42, 43, 44, 46, 54, 57, 61, 

62, 63, 64, 73, 75, 76, 83, 103, 124, 125, 133, 

134, 135, 136, 137, 139, 140, 145, 146, 147, 

148, 152, 170, 172, 192

F

family unit 50, 51, 52, 53, 54, 186, 188, 189

Federal Audit Clearinghouse (FAC) 17, 18, 94, 95, 

124, 125, 126

Federal Financial Report (FFR) 79, 80, 128, 175

Federal Poverty Guidelines 7, 51, 52, 54, 152, 186

Federal Register 51, 65, 188

fees 8, 13, 23, 28, 30, 47, 66, 178

fringe benefits 23, 28, 109, 156, 189

G

grant period 11, 37, 100, 103, 108, 131, 170, 172, 

175, 177

Grants.gov 7, 16, 17, 18, 19, 20, 27, 86, 91, 94

GrantSolutions 7, 18, 19, 20, 37, 76, 77, 79, 83, 86, 

91, 94, 95, 128, 129, 131, 132, 175, 187, 190

grassroots lobbying 72, 73, 74

I

indirect costs 13, 24, 25, 26, 27, 28, 71, 111, 112, 

158, 159, 179, 189

Individual Taxpayer Identification Number 

(ITIN) 42, 63, 137, 138, 189, 193

intake 43, 50, 51, 85, 113, 187, 189

Interim Report 3, 75, 78, 79, 128, 129, 151, 160, 170

K

key personnel 7, 15, 38, 78

L

Legal Services Corporation (LSC) 75, 125, 128, 168, 

169

Limited Entry of Appearance 59, 189

LITC Grantee Conference 23, 37, 41, 45, 83, 109

LITC Program Office 9, 16, 20, 21, 23, 26, 31, 32, 33, 

34, 45, 77, 80, 81, 82, 83, 86, 88, 91, 94, 96, 

103, 128, 138, 145, 173, 174, 186, 187, 190, 

191, 192, 193

Lobbying Restrictions 63, 72

Local Taxpayer Advocate (LTA) 59, 73, 83, 84, 85, 

187, 189

logo(s) 43, 90

Low Income Taxpayer Clinic (LITC) 1, 2, 3, 4, 5, 6, 

7, 8, 9, 10, 11, 13, 14, 15, 16, 17, 18, 19, 21, 22, 

23, 24, 25, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 

37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 50, 

51, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 

65, 66, 67, 68, 69, 70, 71, 73, 74, 75, 76, 77, 78, 

79, 80, 81, 82, 83, 84, 86, 87, 88, 89, 90, 103, 

129, 133

low-income taxpayer, defined 7

M

matching funds 4, 5, 21, 25, 28, 29, 30, 65, 74, 78, 

81, 84, 88, 108, 109, 110, 113, 160, 190

allowable uses 21, 22, 47, 73, 175

on application and reporting forms 108, 109, 

110, 111, 112, 155, 156, 157, 158, 159, 160

prohibited uses 72, 73, 112, 159

requirement 13, 22, 27, 28, 29, 34, 41, 68, 73, 

108, 112

shortfall 27

mentoring 8, 35, 44

N

name change 20

National Taxpayer Advocate (NTA) 3, 6, 34, 35, 73, 

82, 89, 189, 190

networking 42, 44

nominal fee 4, 8, 13, 28, 63, 137
198 LOW INCOME TAXPAYER CLINICS

Non-Competing Continuation (NCC) Request 16, 

18, 20, 21, 33, 34, 94, 95, 96, 97, 103, 108, 124, 

186, 190

O

Office of Management and Budget (OMB) 17, 18, 30, 

51, 65, 67, 80, 84, 87, 90, 91, 94, 95, 96, 186, 

190, 193

operational review visit 84, 85, 191

orientation visit 83, 84, 85, 191

outreach 7, 8, 11, 23, 32, 42, 43, 44, 45, 48, 50, 58, 

64, 85, 133, 134, 137, 187, 191

P

Payment Management System (PMS) 31, 70, 71, 72, 

87, 155, 175, 191

pro bono panel 8, 46, 62, 68, 138

program income 28, 47, 178

program plan 7, 8, 32, 34, 76, 78, 95, 124, 125, 170

program to inform 64

Project Abstract 18, 69, 76, 90, 95, 124, 125

publicity 23, 32, 42, 45, 74

Q

Qualified Business Administrator (QBA) 7, 22, 38, 

78, 104, 125, 187, 191

qualified law graduate 59

qualified representative 8, 29, 46, 192

Qualified Tax Expert (QTE) 7, 23, 38, 41, 62, 78, 

104, 187, 192

R

recordkeeping 7, 47, 49, 61, 64, 84

referral 4, 8, 9, 43, 46, 50, 62

repayment 81

reporting responsibilities 11, 75

S

site assistance visits 82, 84, 88

special appearance authorization 8, 59, 60, 83, 86, 

139, 192

Standard Form

424 13, 14, 17, 18, 76, 94, 95, 96, 97, 102

425 79, 128, 131, 155, 175, 176, 179, 180

standards of operation 38, 65, 192

start-up expenses 22

state tax issue(s) 138

student(s)

as volunteers 138

authorization 8, 9, 59, 60

representation by 4, 28, 48, 49, 57, 59, 60, 83, 

139

valuation 138

subgrant 11

supplemental funding opportunity iii, 3

System for Award Management (SAM) 15, 16, 19, 20, 

86, 88, 97, 103

systemic advocacy 145, 192

Systemic Advocacy Management System (SAMS) 63, 

145, 192

T

Tax Compliance Officer (TCO) 14, 17, 19, 95, 104, 

193

Tax Counseling for the Elderly (TCE) 63, 193

tax library 40

taxpayer return information

unauthorized disclosure 44

tax return 13, 63, 64, 133, 137

See also tax return preparer, tax return preparation

tax return preparation 42, 45, 50, 63, 64, 137, 193, 

194

See also tax return, tax return preparer

tax return preparer 45, 48, 62, 63, 137

See also tax return, tax return preparation

technical assistance consultation 44, 136, 193

termination of a grant 89
LOW INCOME TAXPAYER CLINICS 199

INDEX

VII APPENDICES I II III IV

V VI INDEX

third-party in-kind contributions 13, 28, 110, 157, 

165, 193

travel 23, 26, 41, 84, 109, 157

reporting, example of 168, 169

U

unallowable expenses 21, 23, 108, 193

Uniform Guidance 9, 21, 22, 24, 25, 26, 27, 31, 47, 

65, 88, 89, 108, 111, 112, 191

Unique Entity Identifier (UEI) 11, 19, 20, 193

unused funds 89, 160, 166, 169, 193

V

Volunteer Income Tax Assistance (VITA) 43, 44, 50, 

63, 119, 194

volunteer(s) 13, 22, 23, 27, 28, 29, 30, 32, 36, 38, 39, 

44, 46, 49, 62, 75, 89, 111, 112, 118, 122, 133, 

138, 153, 156, 159, 194

services provided by 8, 28, 29, 39, 111, 153, 165

W

withdrawal from the LITC Program 79, 89

withdrawing applications 19

Y

Year-End Report 34, 48, 49, 50, 54, 57, 75, 76, 79, 80, 

83, 86, 89, 128, 129, 149, 151, 160, 170, 171, 

172, 177, 187

deadline 3, 128

late submission of 80
200 LOW INCOME TAXPAYER CLINICS

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Publication 3319 (Rev. 5-2024) Catalog Number 26939S Department of the Treasury Internal Revenue Service www.irs.gov