Recordkeeping Requirements (Pub 3319 and Form 13424-F)

Low-Income Taxpayer Clinic Grant Application Package

p3319--2025-05-00

Recordkeeping Requirements (Pub 3319 and Form 13424-F)

OMB: 1545-1648

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2026 Grant Application Package and Guidelines

TABLE OF CONTENTS

MAY 2025
DEAR PROSPECTIVE LOW INCOME TAXPAYER CLINIC GRANT APPLICANT:
I am pleased to announce the opening of the 2026 Low Income Taxpayer Clinic (LITC) program. The grant
application period will open on May 15, 2025, and close on July 14, 2025, at 11:59 p.m. Eastern Time (ET).
We are committed to expanding access to representation and education for low-income and English as a
second language (ESL) taxpayers. Our objective for the 2026 grant year is to enhance geographic coverage
and reach more taxpayers by supporting new and existing clinics. The work of the LITCs has a significant
impact on the taxpayers they serve. In 2023, IRS-funded tax clinics:
n Assisted

over 20,000 low-income taxpayers in resolving IRS-related issues;

n Provided

consultations to more than 17,000 taxpayers;

n Conducted

over 1,800 educational activities, reaching nearly 92,000 taxpayers on a variety of tax

topics, including taxpayer rights and responsibilities; and
n Elevated

137 systemic issues to the Taxpayer Advocate Service, promoting fairness and integrity

across the tax system for all taxpayers.
For fiscal year (FY) 2025, Congress has appropriated $28 million in grant funding for the LITC program, with
a maximum award of up to $200,000 per clinic. 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 2026 LITC grants, we will
continue to work toward the following program goals:
n Expanding

service in areas with high IRS compliance activity but limited access to LITC

representation; and
n Increasing

taxpayer education in underserved communities where access to accurate information

about taxpayers’ rights and responsibilities is lacking.
Eligibility and Application Process
Eligibility requirements and application instructions are detailed in IRS Publication 3319. Applications
must be submitted electronically through the LITC Grants Portal by the deadline. The IRS may award
grants to qualifying organizations for a period of up to three years; however, funding is subject to annual
congressional appropriations. 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.
All federal funds provided by the IRS must be matched dollar-for-dollar with non-federal sources or third-party
in-kind contributions. The cost of preparing and submitting applications is the responsibility of each applicant.
Support for Applicants
The LITC Program Office will host informational webinars:
n May

8, 2025, from 1:00 pm to 3:00 p.m. ET

n May

22, 2025, from 1:00 pm to 3:00 p.m. ET

LOW INCOME TAXPAYER CLINICS

These sessions are designed for organizations interested in submitting a new application or learning
more about the process. To register please visit the LITC Grants website. Existing clinics submitting a
Continuation Request should refer to the LITC Toolkit for relevant guidance, session dates and specific
instructions.
Award Notification and Conference Attendance
Qualified applicants will be notified of award decisions by November 2025. All award recipients are required
to attend the Annual LITC Grantee Conference in December 2025. 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 or by
email at LITCProgramOffice@irs.gov.
We appreciate your interest in the LITC Program, and we look forward to a successful 2026 grant year and
continuing our shared mission of ensuring access to justice and fairness in the tax system for low-income
and ESL taxpayers.
Sincerely,

Erin M. Collins
National Taxpayer Advocate

LOW INCOME TAXPAYER CLINICS

COMMON ERRORS

To assist with the application process, see the list below of commonly made errors and missteps. Please
double check your application to avoid these errors and ensure your application is timely processed and
reviewed.

Standard Form 424
n Returning

multiyear applicants requesting the wrong budget period.

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 There

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

transportation, and meals and incidentals.

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

iii

TABLE OF CONTENTS
COMMON ERRORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
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 New Grant Applications and Continuation Requests . . . . . . . . . . . 16
i.

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

ii. Submitting a New Grant Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
iii. Instructions for Completing New Grant Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
iv. Submitting a Continuation Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
v. Instructions for Completing a Continuation Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
vi. Withdrawing Applications After Submission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
C. System for Award Management Registration Requirement and Unique Entity Identifiers . . . . 19
i.

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

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

LOW INCOME TAXPAYER CLINICS

TABLE OF CONTENTS

iii. Unique Entity Identifier . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
iv. Organization Name Change Requests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
D. Submission Due Dates and Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
i.

Due Date for LITC New Grant Applications and Continuation Requests . . . . . . . . . . . . . . 20

ii. Incomplete or Late LITC New Grant Applications and 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 New Grant Applications and Scoring Criteria . . . . . . . . . . . . . . . . . . . 32
B. LITC Program Office Evaluation and Selection of New Grant Applications and
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
x. Recruiting and Supervising Volunteers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
xi. Recordkeeping and File Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
xii. Representing Low-Income Taxpayers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
xiii. Education . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
xiv. Advocacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

LOW INCOME TAXPAYER CLINICS

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80

VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT . . . . . . . . . . . . . . . . . . . . . . 82
A. Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
B. Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
C. Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
D. Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
E. Site Assistance Visits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
F. Contacting the LITC Program Office . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85

VIII. AWARD MODIFICATION, SUSPENSION, TERMINATION, OR WITHDRAWAL . . . . . . . . 87

FEDERAL GRANT ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

LOW INCOME TAXPAYER CLINICS

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
n Offer

dollar-for-dollar matching funds; and

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 2025 grant year, however, there are several geographic areas of the country without an LITC or
with very limited coverage. Thus, in awarding 2026 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
2

See Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, Division Q, § 401, 129 Stat. 2242, 3117 (Dec. 18, 2015).
See IRC § 7803(a)(3)(I).

LOW INCOME TAXPAYER CLINICS

Areas of Special Consideration
Hawaii, Kansas, Montana, and West Virginia currently do not have an LITC. In addition, three states – Florida,
Nevada and South Dakota – have only partial coverage. The uncovered counties in Florida are Brevard, Citrus ,
Glades, Hamilton, Hardee, Hendry, Hernando, Highlands, Indian River, Lafayette, Lake, Madison, Martin, Nassau,
Okeechobee, Orange, Osceola, Polk, Seminole, St. Johns, St. Lucie, Sumter, Suwannee, Taylor, and Volusia.
The uncovered counties in Nevada are Carson City, Churchill, Douglas, Esmeralda, Eureka, Humboldt, Lander,
Lincoln, Lyon, Mineral, Nye, Pershing, Storey, White Pine, and Elko. The uncovered counties in South Dakota
are Aurora, Beadle, Bennett, Bon Homme, Brookings, Brown, Brule, Buffalo, Butte, Campbell, Charles Mix, Clark,
Clay, Codington, Corson, Custer, Davison, Deuel, Dewey, Douglas, Edmunds, Fall River, Faulk, Grant, Gregory,
Haakon, Hamlin, Hand, Hanson, Harding, Hughes, Hutchinson, Hyde, Jackson, Jerauld, Jones, Kingsbury, Lake,
Lawrence, Lincoln, Lyman, McCook, McPherson, Meade, Mellette, Miner, Minnehaha, Moody, Oglala Lakota,
Pennington, Perkins, Potter, Sanborn , Shannon, Spink, Stanley, Sully, Todd, Tripp, Turner, Union, Walworth,
Yankton, and Ziebach.

Figure 1, 2025 LITC Coverage by County

LOW INCOME TAXPAYER CLINICS

LITC PROGRAM DESCRIPTION

Important Dates for 2026 LITC Grant Program
Application Period

May 15-July 14, 2025

New Applicant Webinar, Session 1

May 8, 2025

New Applicant Webinar, Session 2

May 22, 2025

Returning Applicant/Continuation Request Webinar

May 15 and May 20, 2025

Application Q&A Webinar

July 8, 2025

Application Review and Evaluation

July-October 2025

Notification of Selection/Non-Selection

November 2025

Grant Year

January 1-December 31, 2026

Interim Report Due

July 31, 2026

Year-end Report Due

March 31, 2027

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 2025 there are 138 clinics
funded with nearly $20 million. 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 2025
appropriations legislation. 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.

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

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

LITC PROGRAM DESCRIPTION

(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

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

LITC PROGRAM DESCRIPTION

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, reference those activities delivered directly to
taxpayers. Educational activities may also include a workshop or free training for organizations that assist lowincome or ESL taxpayers. While activities delivered to organizations are not included in the numerical goals on
Form 13424-M, these activities will be included in interim and year-end progress reports 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.
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
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.

LOW INCOME TAXPAYER CLINICS

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
n A

attorney;

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.

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.

LOW INCOME TAXPAYER CLINICS

LITC PROGRAM DESCRIPTION

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.

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. Given
the timing of appropriations, grant funds may not be made available to grant recipients until after the grant year
has begun. Figure 2 explains how the LITC Program receives its funding.

Figure 2, How the LITC Program Receives Its Funding

How the LITC Program Receives Its Funding
Step Four
Step Three
Step Two

Step One
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
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

LOW INCOME TAXPAYER CLINICS

FEDERAL AWARD INFORMATION

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.

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 ESL Education Program, under which a grant may be awarded to operate a program to inform
ESL taxpayers about their taxpayer rights and responsibilities.

LOW INCOME TAXPAYER CLINICS

AWARD ELIGIBILITY REQUIREMENTS

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, 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.

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.
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., 2025, 2024, 2023, 2022, 2021);

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

AWARD ELIGIBILITY REQUIREMENTS

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 suspension4
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 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.

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.

LOW INCOME TAXPAYER CLINICS

IV. APPLICATION AND SUBMISSION PROCESS

A. ACCESSING THE LITC GRANT APPLICATION PACKAGE AND
GUIDELINES
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. Begin by registering on
Grants.gov to access the Notice of Funding Opportunity. An organization must also register with SAM to submit
a grant application. 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 NEW GRANT APPLICATIONS AND
CONTINUATION REQUESTS
i.

Determining Type of Application

There are two types of LITC grant applications: LITC New Grant Applications and Continuation 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, 2025, must submit a New Grant Application to apply for
2026 funding. See Section IV.B.ii, Submitting a New Grant Application.

n A

returning clinic funded with a multiyear LITC grant that ends after December 31, 2025, must submit a
Continuation Request to be considered for 2026 funding. See Section IV.B.iv, Submitting a
Continuation Request.

ii. Submitting a New Grant Application
LITC New Grant Applications must be submitted electronically via https://litcgrants.treasury.gov. In the LITC
Grants Portal, applicants will be prompted to create an application and select the type- new or Continuation. The
LITC Program Office will provide annual training on how to use the LITC Grants Portal to submit Continuation
Requests and progress reports. Additional questions regarding the Portal may be directed to the Program Office at
LITCProgramOffice@irs.gov.
The Funding Opportunity Number for the 2026 LITC Grant Application is TREAS-GRANTS-042026-001.

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APPLICATION AND SUBMISSION PROCESS

iii. Instructions for Completing New Grant Application
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.
A complete New Grant Application consists of these items, submitted through the LITC Grants Portal and
prepared in accordance with the instructions:
n Standard

Form 424, Application for Federal Assistance;

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
n The

Education Program applicants must self-identify, see I.A.

following attachments are also required:

n Tax-exempt
n Proof

determination letter, if applicable;

of academic accreditation, if applicable;

n Most

recent audited ﬁnancial statement. 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 Program grant.

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iv. Submitting a Continuation Request
A returning clinic funded with a multiyear LITC grant that ends after December 31, 2025, must submit a
Continuation Request via the LITC Grants Portal. The LITC Program Ofﬁce will provide application training,
and additional questions may be directed to the Program Ofﬁce at LITCProgramOffice@irs.gov.

v. Instructions for Completing a Continuation Request
A complete Continuation Request consists of the following items, submitted through LITC Grants Portal and
prepared in accordance with the instructions:
n Standard

Form 424, Application for Federal Assistance;

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, noting only the following
information:
n Substantial

changes to the program plan; and

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; and

n Civil
n The

Rights Review responses.

following attachments are also required:

n Most

recent audited ﬁnancial statement 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

n Indirect

cost rate agreement, if applicable.

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APPLICATION AND SUBMISSION PROCESS

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.

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 Common Errors.

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 at 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.

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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 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 IRS.gov.

iii. Unique Entity Identifier
Organizations must provide a Unique Entity Identiﬁer (UEI) with the grant application. The UEI is assigned and
managed through SAM. For those already registered in SAM, timely annual renewal is required. The process has
multiple steps and can take up to 14 days to complete.

iv. Organization Name Change Requests
All sponsoring organization name changes are processed through SAM. 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
i.

Due Date for LITC New Grant Applications and Continuation Requests

To be considered for 2026 LITC grant funding, grant applications must be submitted by 11:59 p.m. ET on
July 14, 2025. The time and date of the email conﬁrmation from the LITC Grants Portal acknowledging
application submission serves as evidence that the Grant Application was timely submitted and should be retained
by the applicant.

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APPLICATION AND SUBMISSION PROCESS

ii. Incomplete or Late LITC New Grant Applications and 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 New Grant Application, or Section IV.B.v, Instructions for Completing Continuation
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

LOW INCOME TAXPAYER CLINICS

using matching funds. However, IRC § 7526(c)(5) speciﬁcally prohibits indirect expenses, including general
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 200,5 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 new 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.

See 2 CFR Part 1000.

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APPLICATION AND SUBMISSION PROCESS

Figure 3, Allowable and Unallowable Expenses
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.

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Allowable Expenses

Unallowable Expenses

Travel cost incurred for up to two individuals (or a
third person if granted an exception by the Director
of the LITC Program) to attend the Annual LITC
Grantee Conference. See 2 CFR § 200.475.

Costs determined using an unreasonable method of
allocation. See 2 CFR § 200.405(a)(2).

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

Fundraising costs. See 2 CFR § 200.442.

Legal research and reference materials,
including the IRC and Treasury Regulations.
See 2 CFR § 200.454(b).

Entertainment costs. See 2 CFR § 200.438.

Indirect costs paid with federal funds.
See 2 CFR § 200.414.

Fines and penalties. See 2 CFR § 200.441.

Attending tax training meetings and webinars.
See 2 CFR § 200.473.

An individual’s membership in a professional
organization (e.g., the ABA). See 2 CFR §§ 200.454
and 200.403(b)6.

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.

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:

An individual’s dues to a professional organization may be allowable if the following requirements are met: the dues are
paid as a fringe benefit, payment as a fringe benefit is consistent with the employer’s written policy or contract, the payment
of the cost meets the “reasonableness“ requirements outlined in 2 CFR 200.404, and the payment of the cost meets the
“allocability” requirements outlined in 2 CFR 200.405.

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APPLICATION AND SUBMISSION PROCESS

[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.
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
n Legal

supplies; and

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).

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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.
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.

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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.

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
n Not

from the grant recipient’s records. See 2 CFR § 200.306(b)(1);

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
n In

for in the grant recipient’s approved budget. See 2 CFR § 200.306(b)(6); and

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.

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Figure 4, Qualified and Ineligible Matching Funds
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,
supplies, and other products such as software and
subscriptions.
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.

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

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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).

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:7
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;

See 2 CFR § 1000.306.

LOW INCOME TAXPAYER CLINICS

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.

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 2025 calendar year, the maximum rate is $250 per hour, as prescribed in Revenue Procedure
2024-40, 2024-45 I.R.B. 1100, 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
Federal Audit Clearinghouse (FAC) at https://harvester.census.gov/facweb. 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;

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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

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.

LOW INCOME TAXPAYER CLINICS

V. APPLICATION REVIEW

A. TECHNICAL EVALUATION OF NEW GRANT APPLICATIONS AND
SCORING CRITERIA
Technical Evaluation
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 percent. 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 New Grant Application using the
criteria listed below and award percentage 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. Percentage points will be assigned as follows:

Experience (Maximum 10 percent)
Experience in operating an LITC or delivering representation and education services to low-income and ESL
taxpayers.

Financial Responsibility (Maximum 10 percent)
Quality of grant administration and internal accounting procedures.

Program Performance Plan and Program Coverage (Maximum 80 percent)
Quality of the program plan offered to assist low-income and ESL taxpayers. Evaluation criteria include:
n Qualiﬁcations,
n Amount

training, and supervision of the clinic staff, students, and volunteers;

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

APPLICATION REVIEW

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. It is important that a submission contains all required information to
achieve the maximum score. See new guidance for assistance completing Form 13424-M at
www.TaxpayerAdvocate.irs.gov/about-us/litc-grants.

Figure 5, Grants Evaluation Breakdown of Scoring
Section

Full LITC %

ESL Education %

Background/Experience

10%

Financial Responsibility

10%

Taxpayer Access, Geographic Coverage, &
Outreach

13%

Taxpayer Services

10%

13%

Staffing

17%

14%

Volunteers

20%

Training and Resources

Program Eval and Improvement

Program Numerical Goals

Clinic Operations

B. LITC PROGRAM OFFICE EVALUATION AND SELECTION OF NEW
GRANT APPLICATIONS AND CONTINUATION REQUESTS
i.

LITC Program Office Evaluation

New Grant Applications that earn a score of 50 percent 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 new application such as an organization’s
website and accreditation or professional licensure websites. The Program Ofﬁce will also review and evaluate

LOW INCOME TAXPAYER CLINICS

Continuation 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 New 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;

n Soundness
n Any

of the proposed budget; and

signiﬁcant concerns identiﬁed during the technical evaluation.

Evaluation of Continuation Requests
The LITC Program Office will review all Continuation 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 Continuation Request will receive a new 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 Continuation 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 Continuation 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 2026.

Additional Considerations
Whether to award grant funds will be based on the technical evaluation (for New 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
n The

of services that the clinic will provide;

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;

LOW INCOME TAXPAYER CLINICS

APPLICATION REVIEW

n Other
n The

sources of funding available to the clinic;

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.

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
n Training

technical assistance;

and mentoring other LITCs;

n Publishing

articles about the LITC Program or on tax topics that impact low-income and ESL taxpayers;

n Commenting
n Mentoring

on proposed Treasury regulations that affect low-income or ESL taxpayers; and

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 New Grant Applications receiving a ranking panel score of 50 percent or higher and all Continuation Requests
undergo a civil rights compliance review by the IRS 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 IRS will review all grant applications meeting the above-referenced criteria. To the extent necessary to make a
civil rights compliance determination, the LITC Program Ofﬁce may request that an applicant provide additional

LOW INCOME TAXPAYER CLINICS

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;

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; and

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.

Upon completion of the application reviews, the IRS will forward to the LITC Program Ofﬁce a preliminary civil
rights determination based on the information in the New Grant Application, Continuation Request, and any
other information the IRS received from the grant recipient. If an applicant has provided incomplete information,
the Program Ofﬁce may request additional information from the applicant. No LITC grant funding may be
awarded until the IRS has made its ﬁnal determination.
The IRS annually conducts selected post-award reviews to ensure civil rights requirements are in place and to
provide technical assistance. The IRS 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.

LOW INCOME TAXPAYER CLINICS

VI. AWARD ADMINISTRATION

A. NOTIFICATION OF SELECTION
The LITC Program Ofﬁce will notify all applicants by November 2025 about whether they have been selected
to receive a 2026 grant award. Selected applicants will be notiﬁed by phone and email. If Congress has passed
ﬁnal appropriations legislation for the 2026 ﬁscal year by November 2025, notiﬁcation of selection will include
the amount of the award. If Congress has not passed ﬁnal appropriations legislation for the 2026 ﬁscal year by
November 2025, 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 the LITC Grants Portal.

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 new 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.

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 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

AWARD ADMINISTRATION

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.

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 2026 will be held on May 8 and May 22, 2025, from 1:00 to 3:00 p.m. ET. Details and registration
information will be available at https://www.taxpayeradvocate.irs.gov/about-us/litc-grants. Another webinar will
be presented to returning grant recipients on May 15 and May 20, 2025, from 1:00 to 3:00 p.m. ET and will
focus on changes to the application process and how to submit an Continuation Request. This webinar will be
announced on the LITC Toolkit. An application Q&A webinar for all applicants will be held on July 8, 2025,
from 1:00 to 2:00 p.m. ET. Details about this session will be provided on https://www.taxpayeradvocate.irs.gov/
about-us/litc-grants 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 bar associations. 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

AWARD ADMINISTRATION

iii. Annual Low Income Taxpayer Clinic Grantee Conference
Applicants notiﬁed they have been selected to receive a 2026 grant award must attend the Annual LITC Grantee
Conference, which will be held in December 2025. 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.

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 needs, and how the taxpayer can easily locate
information about the clinic and its services.
Publicity materials and announcements to advertise LITC services must focus on core services:
n Representation
n Consultations
n Education
n Advocacy

in controversy cases;

about tax matters;

about taxpayer rights and responsibilities; and

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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AWARD ADMINISTRATION

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 1402,8 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 or workforce development; 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.

Pub. L. No. 116-25, § 1402, 133 Stat. 981, 997 (July 1, 2019).

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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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.

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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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
n When
n What

individuals have approval authority;

written approval is required; and
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;

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
n Analysis

of underlying facts (briefly describing the subject matter and information);

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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AWARD ADMINISTRATION

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.

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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AWARD ADMINISTRATION

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 90 Fed. Reg. 5917 (Jan. 17, 2025).

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

$39,125

$48,875

$44,975

$52,875

$66,075

$60,800

$66,625

$83,275

$76,625

$80,375

$100,475

$92,450

$94,125

$117,675

$108,275

$107,875

$134,875

$124,100

$121,625

$152,075

$139,925

$135,375

$169,275

$155,750

For each additional person, add

$13,750

$17,200

$15,825

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
n Net

salaries before payroll deductions;

earnings from self-employment (gross receipts less business expenses);

n Alimony;
n Child

support;

n Federally-funded
n Social

and other public assistance;

Security;

n Pensions

and retirement income;

n Unemployment
n Workers’

beneﬁts;

compensation;

n Rents;
n Royalties;
n Scholarships;
n Dividends;
n Interest;

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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
n Tax

from a bank account;

refunds;

n Gifts;
n Loans;
n Lump

sum inheritances;

n Insurance
n Noncash

payments; and

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.

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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AWARD ADMINISTRATION

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).

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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AWARD ADMINISTRATION

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.

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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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.

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.

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

LOW INCOME TAXPAYER CLINICS

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 email theLITCProgramOffice@irs.gov. or call 202-317-4700.

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
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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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
n IRS

spouse relief;

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:

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. 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 considering their needs. 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.

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
n Responding

in advocacy projects with professional organizations;

to public requests for comments to IRS regulations, procedures, or guidance;

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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.
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.

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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;

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;

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n Other

guidance issued by OMB after the New Grant Application or Continuation 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.

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Digital Accountability and Transparency Act of 2014
The Digital Accountability and Transparency Act of 2014 (the Data Act, Pub. L. No. 113-101, 128 Stat. 1146
(May 9, 2014)) requires the U.S. Department of the Treasury to establish common standards for financial data
provided by all government agencies on the USASpending website (or successor system) 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:
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
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.

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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).

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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
n The

on political activities (18 U.S.C. §§ 595, 598, 600-603);

national preservation program requirements (54 U.S.C. § 300101);

n Whistleblower
n Rules

governing allowable costs (41 U.S.C. §§ 4304 and 4310);

n Environmental
n The

protections (41 U.S.C. § 4712);
requirements of the Clean Air Act (42 U.S.C. § 7401); and

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.)
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).

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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).

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.

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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;

LOW INCOME TAXPAYER CLINICS

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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.

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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

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

Type of Funds
Affected by
Restriction

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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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

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 the LITC Grants Portal. The LITC
Program Ofﬁce provides annual training on using the LITC Grants Portal. These trainings are announced on the
LITC Toolkit.

Completing the Application Amendment
Application amendments are completed and submitted in the LITC Grants Portal. An application amendment
is required by all grant recipients, even if the grant recipient is not changing the budget or program
performance plan.
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. If the amount requested is received, then the
grant recipient will resubmit the budget provided with the application. 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.
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 application amendment may 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. The Program Office
will offer a training session about the application amendment process; the date and time will be announced on the
LITC Toolkit.

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

Events Requiring Notification to the LITC Program Office

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 package, the
Advocacy Analyst will return the package to the grant recipient via LITC Grants Portal 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.

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.

LOW INCOME TAXPAYER CLINICS

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).

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

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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 LITC Grants Portal by July 31, 2026. The Interim Report covers
the first half of the grant year (January 1, 2026 through June 30, 2026) 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 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.

LOW INCOME TAXPAYER CLINICS

iii. Submitting the Year-end Report*
A Year-end Report must be submitted online through LITC Grants Portal by March 31, 2027. The Year-end
Report covers the entire grant year (January 1, 2026 through December 31, 2026).
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 Program only, you are required to submit the following at interim and yearend: 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
n Reduction

or termination of the grant; or

of any future award amount.

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.

LOW INCOME TAXPAYER CLINICS

AWARD ADMINISTRATION

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
n Providing

the award and payment of grant funds;

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.

B. ADMINISTRATION
The LITC Program Office administers the grant by:
n Processing
n Revising

LITC grant applications and making awards to successful applicants;

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.

LOW INCOME TAXPAYER CLINICS

LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT

C. ASSISTANCE
The LITC Program Ofﬁce assists by:
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
n Assisting

grant recipients’ access to e-Services products offered by the IRS; and

with resolution of problems that grant recipients may experience with LITC Grants Portal.

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;

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

LOW INCOME TAXPAYER CLINICS

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
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

LOW INCOME TAXPAYER CLINICS

LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT

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.

F. CONTACTING THE LITC PROGRAM OFFICE
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

8:00 a.m. - 4:30 p.m. ET Mon. - Fri.

Phone

202-317-4700

E Fax

877-477-3520

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

202-317-4700

E Fax

877-477-3520

LOW INCOME TAXPAYER CLINICS

OTHER RESOURCES
System for Award Management (SAM.gov)
Website

www.sam.gov

Phone Support

866-606-8220

Accessing the Notice of Funding Opportunity
Website

www.grants.gov

Phone Support

800-518-4726

Email Support

support@grants.gov

Submission of a New or Continuation Request and Interim/Year-end Reports via LITC Grants Portal
Website

www.LITCgrants.treasury.gov

Email Support

LITCProgramOffice@irs.gov

Department of Health and Human Services (HHS) Payment Management System (PMS)
Website

https://psc.hhs.gov

Phone Support

877-614-5533

Email Support

PMSSupport@psc.gov

2 CFR Part 200 (OMB Guidance) and
2 CFR Part 1000 (Treasury Department Adoption of OMB Guidance)
www.ecfr.gov
Website

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)
Publication 3319, LITC Grant Application Package and Guidelines

LITC Program Publications

Publication 4134, Low Income Taxpayer Clinic List
Publication 5066, Low Income Taxpayer Clinic (LITC) Program Report

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;

LOW INCOME TAXPAYER CLINICS

n Initiate

suspension or debarment proceedings as authorized under 2 CFR Part 180;

n Withhold
n Take

a future award amount; or

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

AWARD SUSPENSION OR TERMINATION

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:
Form Number

Time Burden

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

LOW INCOME TAXPAYER CLINICS

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. Grant Applications must be submitted through LITC Grant
Portal. 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)

LOW INCOME TAXPAYER CLINICS

FEDERAL GRANT ACRONYMS

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

DoD

Department of Defense

DUNS

Data Universal Numbering System

Enrolled Agent

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

MIE

Meals and Incidental Expenses

MTDC

Modified Total Direct Costs

LOW INCOME TAXPAYER CLINICS

FEDERAL GRANT ACRONYMS

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.

LOW INCOME TAXPAYER CLINICS

GLOSSARY

LOW INCOME TAXPAYER CLINICS

GLOSSARY

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
2025, the Federal Poverty Guidelines were published at 90 Fed. Reg. 5917 (Jan. 17, 2025).

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 New Grant Application or a Continuation 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

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.

C
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.
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.
Continuing Professional Education (CPE) – an accredited educational program required to maintain a
professional license, such as a Certiﬁed Public Accountant or Enrolled Agent designation.
Continuation Request – a request for LITC grant funding submitted to the LITC Program Ofﬁce through the
LITC Grants Portal.

LOW INCOME TAXPAYER CLINICS

GLOSSARY

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.
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.

LOW INCOME TAXPAYER CLINICS

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.

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:

LOW INCOME TAXPAYER CLINICS

GLOSSARY

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.

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
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

LOW INCOME TAXPAYER CLINICS

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).

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.
Qualified Tax Expert (QTE) – generally, a staff member of the clinic (or a volunteer in the case of the ESL
Education 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

100

LOW INCOME TAXPAYER CLINICS

GLOSSARY

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
n Preparing

on proposed IRS regulations and guidance;

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.

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.

LOW INCOME TAXPAYER CLINICS

101

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.

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.

102

LOW INCOME TAXPAYER CLINICS

www.TaxpayerAdvocate.irs.gov/LITC

Publication 3319 (Rev. 5-2025) Catalog Number 26939S Department of the Treasury Internal Revenue Service www.irs.gov

File Type	application/pdf
File Title	Publication 3319 (Rev. 5-2025)
Subject	Low Income Taxpayer Clinics (LITC) Grant Application Package and Guidelines for 2025
Author	TA:LITC
File Modified	2025-05-15
File Created	2025-05-12