2027 Grant Application Package and Guidelines

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Table of Contents

TABLE OF CONTENTS

LETTER FROM THE NATIONAL TAXPAYER ADVOCATE�� iv

WHAT’S NEW IN GRANT YEAR 2027�� vi

COMMON ERRORS CHECKLIST��vii

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��9

A. Awards Are Subject to Congressional Appropriations�� 9

B. Award Performance Period�� 9

C. Subawards Are Generally Prohibited�� 10

D. LITC Grants Are Not Cooperative Agreements�� 10

III. AWARD ELIGIBILITY REQUIREMENTS�� 11

A. Eligible Applicants�� 11

B. Requirement to Provide Matching Funds Equal to Award �� 11

C. Other Eligibility Requirements ��12

Using Grant Funds to Support Other Activities Is Prohibited ��12

ii. Charging More Than a Nominal Fee for Services Is Prohibited��12

iii. Compliance With Federal Tax and Nontax Requirements ��12

iv. Debarment and Suspension��14

IV. APPLICATION AND SUBMISSION PROCESS ��15

A. Accessing the LITC Grant Application Package and Guidelines��15

B. Required Content for LITC New Grant Applications and Continuation Requests��15

Determining Type of Application ��15

ii. Submitting a New Grant Application ��15

iii. Instructions for Completing a New Grant Application ��15

iv. Submitting a Continuation Request��16

v. Instructions for Completing a Continuation Request��16

vi. Withdrawing Applications After Submission��17

LOW INCOME TAXPAYER CLINICS

C. System for Award Management Registration Requirement and Unique Entity Identifiers��17

i. System for Award Management��17

ii. Employer Identification Number��18

iii. Unique Entity Identifier��18

iv. Organization Name Change Requests��18

D. Submission Due Dates and Times ��18

Due Date for LITC New Grant Applications and Continuation Requests ��18

ii. Incomplete or Late LITC New Grant Applications and Continuation Requests ��18

Budget Considerations and Funding Restrictions �� 19

i. Spending LITC Grant Funds and Matching Funds ��19

ii. Direct vs. Indirect Expenses�� 22

iii. Meeting the Matching Funds Requirement�� 25

iv. Office of Management and Budget Audit Requirement�� 28

V. APPLICATION REVIEW ��30

A. Technical Evaluation of New Grant Applications and Scoring Criteria��30

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�� 40

iv. Developing a Community Outreach Plan��41

v. Building Community Partnerships ��43

vi. Networking With Other Low Income Taxpayer Clinics��43

vii. Mentoring��43

viii. Technical Assistance��44

ix. Maintaining Client Confidentiality ��44

x. Recruiting and Supervising Volunteers �� 45

xi. Recordkeeping and File Management�� 46

xii. Representing Low-Income Taxpayers�� 49

xiii. Education�� 59

LOW INCOME TAXPAYER CLINICS

Table of Contents

xiv. Advocacy��61

xv. Preparing Tax Returns and Individual Taxpayer Identification Number Applications ��61

D. National Policy Requirements and Administrative Requirements�� 62

General Compliance �� 62

ii. Managing Grant Funds �� 67

iii. Lobbying Restrictions�� 69

Reporting Responsibilities�� 72

i. Events Requiring Notification to the LITC Program Office�� 73

ii. Submitting the Interim Report �� 75

iii. Submitting the Year-End Report �� 75

iv. Grant Closeout�� 76

VII. LITC PROGRAM OFFICE RESPONSIBILITIES AND CONTACT�� 77

A. Structure�� 77

B. Administration �� 77

C. Assistance �� 78

D. Oversight �� 78

Site Assistance Visits �� 78

Contacting the LITC Program Office ��81

VIII. AWARD MODIFICATION, SUSPENSION, TERMINATION, OR WITHDRAWAL �� 82

FEDERAL GRANT ACRONYMS�� 85

GLOSSARY�� 87

LOW INCOME TAXPAYER CLINICS

iii

LETTER

MAY

2026

FROM THE NATIONAL TAXPAYER ADVOCATE

DEAR PROSPECTIVE LOW INCOME TAXPAYER CLINIC GRANT APPLICANT:

I am pleased to announce the opening of the 2027 Low Income Taxpayer Clinic (LITC) grant application

period. Applications will be accepted from May 6, 2026, through July 6, 2026, at 11:59 p.m. Eastern Time

(ET). Whether you are applying for the first time or continuing your work with the program, we appreciate

your commitment to serving taxpayers and communities in need.

As you consider applying for the upcoming grant year, we remain committed to expanding access to

representation and education for low-income taxpayers and individuals for whom English is a second

language (ESL). Your work as an LITC plays a vital, mission-driven role in ensuring that all taxpayers,

regardless of income or language spoken, are heard, supported, and treated fairly. In 2027, we aim to broaden

the program’s geographic reach and serve more taxpayers by strengthening existing clinics and supporting

new ones in underserved communities. The work of LITCs is powerful and makes a meaningful difference in

communities across the country. In 2024, IRS-funded LITCs:

Represented more than 21,000 low-income taxpayers in disputes with the IRS;

Provided consultation assistance to over 18,000 taxpayers; and

Conducted more than 20,000 educational activities, reaching over 161,000 individuals on a variety of

tax topics, including taxpayer rights and responsibilities.

Behind each of these numbers is a person or family who gained clarity, representation, and a fair opportunity

to resolve their tax issue. This work matters, and it changes lives.

For fiscal year 2026, Congress appropriated $28 million in funding for the LITC Program, with awards of up

to $200,000 per clinic. These funds support not only direct representation and education but also broader

advocacy efforts that identify and address systemic issues affecting vulnerable taxpayers. Through this

program, we continue to strengthen protections, expand awareness, and advance fairness affecting these

communities.

In awarding 2027 LITC grants, we will continue to focus on:

Expanding services in areas with high IRS compliance activity and significant populations of eligible

taxpayers; and

Increasing taxpayer education in underserved communities where access to reliable information about

rights and responsibilities is limited.

Eligibility and Application Process

Eligibility requirements and application instructions are outlined in IRS Publication 3319. All applications must

be submitted electronically through the LITC Grants Portal by the stated deadline. The IRS may award grants

for up to three years; however, funding is subject to annual congressional appropriations. Generally, first-time

applicants will receive a one-year grant unless otherwise specified in the Notice of Funding Opportunity to

encourage coverage in underserved areas.

LOW INCOME TAXPAYER CLINICS

LETTER FROM THE NATIONAL TAXPAYER ADVOCATE

All federal funds must be matched dollar-for-dollar with non-federal funding or third-party in-kind

contributions. Applicants are responsible for all costs associated with preparing and submitting their

applications.

Support for Applicants

To help you prepare a strong application, the LITC Program Office will host three informational webinars:

Session One: Application Basics: Tuesday, May 12, 2026, 1-3 p.m. ET.

Session Two: LITC Grants Portal Overview and Application Considerations: Wednesday, May 13, 2026,

1-3 p.m. ET.

Session Three: Budget Basics: Tuesday, May 26, 2026, 1-3 p.m. ET.

LITC will also hold Q&A Sessions: Tuesday, June 16, 2026, and Monday, June 29, 2026, 1-2 p.m. ET (no formal

presentation).

These sessions are designed to help organizations understand the program, navigate the application process,

and build strong proposals. To learn more about these sessions, please visit the LITC Grants website. Existing

clinics submitting a new or continuation request should refer to the LITC Toolkit for additional guidance,

training dates, and instructions.

Award Notification and Conference Attendance

Applicants will be notified of award decisions by November 2026. All award recipients are required to attend

the Annual LITC Grantee Conference, which we anticipate holding in December 2026. This conference

provides an important opportunity for new and returning clinics to connect with peers, share best practices,

and deepen expertise on issues affecting low-income and ESL taxpayers. Conference details will be provided

once dates are finalized. If you have questions about the LITC Program or the application process, please

contact the LITC Program Office at 202-317-4700 or via email at LITCProgramOffice@irs.gov.

Thank you for your commitment to serving communities in need. We are inspired by the work of LITCs across

the country and look forward to partnering with you in the year ahead. Together, we will continue advancing

our shared mission of ensuring fairness, dignity, and access to justice in the tax system.

Sincerely,

Erin M. Collins

National Taxpayer Advocate

LOW INCOME TAXPAYER CLINICS

WHAT’S NEW IN GRANT YEAR 2027

This list highlights key changes for the 2027 grant year. All applicants should read the full publication. By

accepting the Notice of Award, grant recipients agree to follow the guidelines in Publication 3319.

FORM 13424-M, LOW INCOME TAXPAYER CLINIC (LITC) APPLICATION

NARRATIVE

The LITC Program Office has revised Form 13424-M and combined it with Form 13424, Low Income Taxpayer

Clinic (LITC) Application Information, to create a single, dynamic form. The form will only display the questions

relevant to the type of clinic selected. To ensure the form displays the correct questions, make sure the clinic

type selected matches the services that the applicant plans to offer.

Clinic Service Type: Choose one of the following:

ESL Education; or

Representation, Education, and Advocacy (also known as a full scope LITC).

Service Delivery Model: If you select Representation, Education, and Advocacy, the options will be:

Representation – Staff (Employees of the LITC will provide a majority of the representation); or

Representation – Volunteer (The LITC will refer volunteers to provide a majority of the

representation). Tip: If you select the “Volunteer” model, provide detailed responses to

questions in that section of the application.

STAFFING SECTION

Indicate if one person will serve in one or more key roles to eliminate reentering the same information such as

email address, telephone number, and credential information.

For the Qualified Tax Expert (QTE), you must provide the individual’s credential (CPA, Attorney, Enrolled

Agent, or Other) information, including state of licensure, license number, and whether licensed to

practice before the U.S. Tax Court.

For 2027, all applicants must complete the new Form 13424-M, but for those submitting Continuation

Requests, the LITC Program Office will provide special instructions via a webinar and presentation materials

made available on the LITC Toolkit.

LOW INCOME TAXPAYER CLINICS

COMMON ERRORS CHECKLIST

To help the application process go smoothly, review these common errors. Double check the application to

avoid these errors and delays in processing and review.

Standard Form 424

If the Unique Entity Identifier (UEI) is not input at the start of the application process, the System for

Award Management (SAM) at www.SAM.gov is unable to validate or auto-populate certain fields.

Whether fields are auto populated or entered manually, be sure the applicant’s name and address

match exactly with SAM records.

Verify all information in SAM before submitting the application.

Form 13424-M

Make sure the audit designation provided in the application matches the designation in the applicant’s

most recent audit report.

For the Civil Rights Review Activity section, do not answer “not applicable.” All questions apply to all

applicants. If no reviews were conducted within the last three years, state that.

Form 13424-J

Returning applicants should base new budgets on the most recent amended budget – not the original –

to ensure that previous errors are not made again.

Provide detailed notes for each expenditure, including breakdowns (e.g., lodging, meals, airfare for travel).

Employer Identification Number (EIN) and SAM Registration

Allow several weeks to obtain an EIN and 501(c)(3) status, if applicable, and to complete a SAM

registration.

An EIN is required to complete the SAM registration process.

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

Missing or Incomplete Attachments

Indirect Cost Rate Agreement (ICRA) is incomplete or expired. To determine whether the ICRA is

properly applied, the LITC Program Office must know which costs are included in Modified Total Direct

Costs, so this part of the agreement must be supplied. If the ICRA is expired, the applicant should

provide an explanation, including whether an extension was requested, and if so, the date requested.

Tax-exempt determination letter (if applicable) is missing.

Letter of accreditation for academic institutions is missing.

Single audit report is incomplete, missing, or not available on the Federal Audit Clearinghouse website.

LOW INCOME TAXPAYER CLINICS

vii

LITC Program Description

I. LITC PROGRAM DESCRIPTION

A. LITC GRANT PROGRAM PRIORITIES

LITCs Provide Representation, Education, and Advocacy

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

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

Educating them about their rights and responsibilities as taxpayers; and

Identifying and advocating for issues that impact these taxpayers.

LITCs must:

Provide dollar-for-dollar matching funds; and

Offer services for free or for a nominal fee. See Section I.D, Key Terms and Definitions.

Taxpayer Bill of Rights

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 is the right to retain representation,2 meaning

taxpayers have the right to retain an authorized representative to represent them in interactions with the IRS.

Taxpayers who are unable to afford representation have the right to be informed of their potential eligibility for free

or low-cost assistance from an LITC 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 continues to expand access to clinic services through onboarding new clinics and allowing for expanded

service delivery models geared to reach areas where the IRS has been unable to attract qualified applicants. Special

consideration will be given to applicants from the following states where there is currently no LITC physically

located within the state: Hawaii, Kansas, Montana, Nevada, South Dakota, West Virginia, and Wisconsin. For

Nevada and South Dakota, clinics in neighboring states provide coverage, but in the remaining states, assistance is

limited and delivered primarily through remote clinics.

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

In addition, some areas within states have limited or no coverage including:

Arizona: Gila County

Florida: Glades County, Hardee County, Hendry County, Hernando County, Highlands County, Indian

River County, Martin County, Okeechobee County, Sumter County

Pennsylvania: Lehigh County, Northampton County

Tennessee: Fayette County, Lauderdale County, Tipton County

Figure 1

2026 LITC Coverage by County

LITC Service

Coverage

Limited Coverage

The Taxpayer Advocate Service (TAS) has developed an interactive map at https://www.taxpayeradvocate.irs.gov/

LITC-map to help identify areas of need. The map provides county level data, including the estimated number of

taxpayers with incomes at or below 250% of the poverty level; the number of compliance activities (common to

low-income taxpayers) conducted by the IRS in that county; and the most common type of compliance activity in

that community. Users can zoom in on specific locations, and hovering over a county will display key metrics for

that area.3

The map uses Housing and Urban Development, Census, and IRS data. These metrics include LITC/Count of LITCs: Name of the LITC or

count of the LITCs providing service in a county; Population: 2020 Census Population (CT uses 2024 data for planning regions); Low-Income

Taxpayers: Count of Tax Year 2024 returns filed with AGI below 250% of the Federal Poverty Level; Compliance Actions: Count of identified

low-income taxpayers with a compliance action in 2024; Most Prevalent Compliance Action: Most prevalent type of IRS compliance action;

and Limited English Proficiency: 2024 Census estimate of the percent of the population having limited English proficiency.

LOW INCOME TAXPAYER CLINICS

LITC Program Description

Important Dates for 2026 LITC Grant Program

Application Period

May 6-July 6, 2026

Session 1: Application Basics

May 12, 2026

Session 2: LITC Grants Portal Overview and Application

Considerations

May 13, 2026

Session 3: Budget Basics

May 26, 2026

Returning Applicant/Continuation Request Webinar

Announcements and links on LITC Toolkit

Q&A Sessions (No formal presentation)

June 16 and June 29, 2026

Application Review and Evaluation

July-October 2026

Notification of Selection/Non-Selection

November 2026

Grant Year

January 1-December 31, 2027

Interim Report Due

July 30, 2027

Year-End Report Due

March 30, 2028

B. HISTORY OF THE LITC PROGRAM

The LITC Program was established in 1998 as part of the IRS Restructuring and Reform Act of 1998 to authorize

funding for the LITC Program.4 The IRS created the LITC Program Ofﬁce in 1999 to manage and administer the

grants and provide guidance, assistance, and oversight to LITCs and prospective applicants. The LITC Program

Ofﬁce operates under the Ofﬁce of the Taxpayer Advocate (commonly referred to as TAS). TAS is led by the

National Taxpayer Advocate, who reports to the IRS Commissioner.

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

The LITC Program has since expanded its coverage, and in 2026, there are 138 clinics funded with nearly $20

million. The LITC Program Ofﬁce’s history of recruiting qualified 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 the passage of the 2023 Appropriations legislation, when it was increased to $200,000 for that year.

That increase has been continued in subsequent appropriations acts. Despite the general funding limitations, 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:

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 lowincome 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.

(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;

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 dollar-fordollar 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% of the taxpayers represented

by a clinic have incomes that do not exceed 250% of the Federal Poverty Level. The LITC Program uses the poverty

guidelines published annually by the Department of Health and Human Services (HHS). 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 pay the correct amount of taxes,

exploring all possible options for relief, and assisting them in making a fully informed decision about how best to

proceed given the facts of the case and the taxpayer’s situation. Notwithstanding the unique nature of each 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

LOW INCOME TAXPAYER CLINICS

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

Taxpayer Advocate. 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. For

purposes of the LITC grant, advocacy does not include lobbying. See Section VI.D.iii, Lobbying Restrictions.

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 take steps to address the controversy, including developing a plan for representation. If the clinic represents a

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

plan 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 also count it as a case if the clinic provides ongoing monitoring and support.

Clinic refers to an LITC. See the deﬁnition of LITC. 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

necessarily 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 for the Earned Income Tax Credit, 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 a 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 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) advise ESL or low-income individuals about their

rights and responsibilities as taxpayers and tax issues of signiﬁcance to the intended audience. To be considered

an educational activity, information about a speciﬁc tax topic or topics must be conveyed to the audience.

LOW INCOME TAXPAYER CLINICS

LITC Program Description

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, 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. Viewers of

recorded materials in the year posted may be counted as additional participants so long as the organization monitors

the platform so that viewers may pose and receive answers to questions. Generally, television and radio appearances

are not counted as educational activities.

ESL taxpayers are individuals for whom English is not their ﬁrst language, including those who communicate

using sign language. These individuals may have an additional challenge in understanding taxpayer rights and

responsibilities. Consistent with IRC § 7526, delivering taxpayer education to ESL taxpayers is a priority. ESL

is different than Limited English Proficiency (LEP). LEP refers 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 notices of 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% of the Federal Poverty Level. The

Federal Poverty Guidelines are updated annually (usually in late January) by the Department of Health and Human

Services. 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.

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 small 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 provides. A nominal fee does

not include reimbursement for actual costs incurred (e.g., photocopies, court costs, 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

LOW INCOME TAXPAYER CLINICS

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:

An attorney;

A CPA;

An EA authorized to practice before the IRS;

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

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, 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; however, the student

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

Revenue Manual (IRM) 1.2.2.15.18.

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

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

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

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

I.R.B. 192.

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

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

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

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

Administrative Requirements, for a more detailed discussion.

Additional terms and definitions are available in the Glossary.

LOW INCOME TAXPAYER CLINICS

FEDERAL AWARD INFORMATION

II. FEDERAL AWARD INFORMATION

A. AWARDS ARE SUBJECT TO CONGRESSIONAL APPROPRIATIONS

All awards depend on 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.

How the LITC Program Receives Its Funding

Figure 2, 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 be awarded only 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 states otherwise. The LITC Program Ofﬁce has discretion to determine the grant period and

may award a single-year grant even if the applicant requested a multiyear grant.

Multiyear grant recipients are reviewed annually to assess performance, progress in meeting goals and objectives,

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

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

with grant terms and conditions, and the availability of annually appropriated funds. Funds awarded must be used

for the program speciﬁcally authorized in the Notice of Award/Funding Award (NOA).

LOW INCOME TAXPAYER CLINICS

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 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. Any subaward must be

included 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 or services to the clinic, which is permissible. For

example, unless authorized, an LITC may not pay another organization to prepare and deliver 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 outside the geographic service area and has capacity to provide services

remotely, such as representation and advocacy services, a subaward to a local organization may be appropriate when

local presence is needed to facilitate client contact and provide in-person education and outreach, and the area to be

served 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 a Unique Entity Identifier (the identifier assigned by SAM.gov). Grant recipients that

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

AWARD ELIgiBILITY REQUIREMENTS

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 1-3 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 an ESL taxpayer education program, the mission of

the LITC Program is best served by requiring all organizations to provide both services. Organizations that can

provide both controversy and education services are generally stronger and able to serve taxpayers more effectively.

For example, organizations sometimes assist taxpayers initially through outreach and education and later through

representation in a controversy; in these cases, the ability to provide both services not only ensures seamless

assistance for taxpayers but also provides extensive protection of taxpayer rights. Thus, the Program Office will

award funds only 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 solely to operate a program that informs ESL taxpayers about their taxpayer rights and responsibilities.

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 creates a financial partnership between the clinic and the federal

government for the benefit of low-income and ESL taxpayers. Matching funds help extend the value of federal

funding so that more taxpayers can be served. Many programs provide matching funds in cash or third-party in-kind

contributions, such as volunteer time, donated software, or office space, that exceed the minimum required amount.

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

Matching Funds Requirement.

LOW INCOME TAXPAYER CLINICS

C. OTHER ELIGIBILITY REQUIREMENTS

Using Grant Funds to Support Other Activities Is Prohibited

An organization awarded an LITC grant may provide qualifying LITC services within a broader range of activity.

For example, a clinic may provide representation in nontax matters such as landlord/tenant disputes or family law

cases and representation in tax matters provided LITC grant funds are used only to support the representation of

eligible taxpayers in 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; see Key Terms and Definitions. The goal of the

LITC Program is to increase 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. If a clinic charges a nominal fee, it must:

Charge that same fee to all taxpayers, regardless of the services being sought;

Not use a sliding scale based on income; and

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, expert witness fees) is not

considered a fee and therefore is 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 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.

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 the applicant is working with someone at the IRS to resolve an

outstanding federal tax issue, they should provide the individual’s name, the office in which they work, and their

phone number when completing 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-M, Low Income Taxpayer Clinic (LITC) Application Narrative, requests contact

LOW INCOME TAXPAYER CLINICS

AWARD ELIgiBILITY REQUIREMENTS

information for the Tax Compliance Ofﬁcer (TCO), the individual responsible for handling the applicant’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 individual responsible for the applicant organization’s federal tax matters. To assist with

resolving potential tax compliance issues and to prevent the IRS from making an unauthorized disclosure, applicants

should 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 listed as TCO on Form 13424-M is

properly authorized to receive tax information. When providing articles of incorporation, ensure it is the most recent

version. When providing Form 2848, be sure of the following:

All required fields are completed;

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

In Section 3, both current and past tax years are listed (e.g., 2025, 2024, 2023, 2022, 2021);

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

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. 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.

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 uses 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 Matters-Primary

LOW INCOME TAXPAYER CLINICS

Covered Transactions. Applying the “common rule” on non-procurement, debarment, and suspension5 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 charged, criminally or civilly, 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. 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

non-procurement transactions under Executive Order 12549. See also Executive Order 12689.

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

IV. APPLICATION AND SUBMISSION PROCESS

A. ACCESSING THE LITC GRANT APPLICATION PACKAGE AND

GUIDELINES

Preparing and submitting a grant application is a major undertaking. Applicants should take time to understand and

review the process well before the application submission deadline and begin the process early. Start by registering for

Grants.gov, where you can set up an alert to be notified when the LITC Notice of Funding Opportunity is posted.

The Notice of Funding Opportunity will also be posted at www.taxpayeradvocate.irs.gov/about-us/litc-grants.

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 next steps.

B. REQUIRED CONTENT FOR LITC NEW GRANT APPLICATIONS AND

CONTINUATION REQUESTS

Determining Type of Application

There are two types of LITC grant applications: LITC New Grant Applications and Continuation Requests.

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

period has ended before or will end on December 31, 2026, must submit a New Grant Application to apply

for 2027 funding. See Section IV.B.ii, Submitting a New Grant Application.

A returning clinic funded with a multiyear LITC grant that ends after December 31, 2026, must

submit a Continuation Request to be considered for 2027 funding. See Section IV.B.iv, Submitting a

Continuation Request.

ii. Submitting a New Grant Application

LITC New Grant Applications must be submitted electronically in the LITC Grants Portal at

https://LITCgrants.treasury.gov. Applicants will be prompted to create an application and select the type: New or

Continuation. Training sessions for applicants submitting a New Application are noted under “Important Dates”

in this publication. The dates, any changes to sessions, and registration or session links will be available on the

TAS website at www.taxpayeradvocate.irs.gov/about-us/litc-grants. Presentation materials will also be posted to the

website after the sessions. Problems or additional questions about working within the portal may be directed to the

LITC Program Office at LITCGrants@treasury.gov.

The Funding Opportunity Number for the 2027 LITC Grant Application is TREAS-GRANTS-052027-001.

iii. Instructions for Completing a New Grant Application

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

IRS also requires specific forms be completed for an LITC grant.

LOW INCOME TAXPAYER CLINICS

A complete New Grant Application consists of the following items, submitted through the LITC Grants Portal and

prepared in accordance with the instructions:

Standard Form 424, Application for Federal Assistance;

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

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

The following attachments are also required:

Tax-exempt determination letter, if applicable;

Proof of academic accreditation, if applicable;

Most recent audited ﬁnancial statement. See Section IV.E.iv, Office of Management and Budget Audit

Requirement. 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;

Indirect cost rate agreement, if applicable; and

Helpful but not required:

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. Providing this information in advance can speed resolution if an issue is discovered.

When completing Form 13424-M, answer all parts of each question. When available, helper text

will appear when hovering over a circle with the letter “i” in the center.

iv. Submitting a Continuation Request

A returning clinic funded with a multiyear LITC grant that ends after December 31, 2026, must submit a

Continuation Request via the LITC Grants Portal. In 2027, clinics requesting continuation will complete a full

Form 13424-M due to the form’s revision and new format. In future years, a continuation request will only require

completion of specific fields and information where there are substantial changes. The Continuation Request

will not undergo a Technical Review. Training for returning clinics submitting a Continuation Request will be

announced on the LITC Toolkit. Questions about application contents may be directed to the Program Ofﬁce at

LITCProgramOffice@irs.gov. Problems working within the portal should be sent to LITCGrants@treasury.gov.

v. Instructions for Completing a Continuation Request

A complete Continuation Request consists of the following items, submitted through the LITC Grants Portal and

prepared in accordance with the instructions:

Standard Form 424, Application for Federal Assistance;

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

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

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

The following attachments are also required:

Most recent audited ﬁnancial statement. See Section IV.E.iv, Office of Management and Budget Audit

Requirement. 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;

Indirect cost rate agreement, if applicable; and

Helpful but not required:

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

of Representative) indicating that the designated TCO is properly authorized to receive tax information.

Providing this can speed resolution if an issue is discovered.

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 through the LITC Grants Portal at LITCGrants@treasury.gov or by emailing

the LITC Program Office at LITCProgramOffice@irs.gov. See Section VII.F, Contacting the LITC Program Office.

New applications that are started but not submitted by the deadline will be treated as incomplete and closed in the

grant system.

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 processes 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.

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 required 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.

LOW INCOME TAXPAYER CLINICS

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

expire and update information as needed. You may update it as often as you want, but you must update it at least

once per year. The process can take several weeks to complete.

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 United States 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. If applying by mail, it can take multiple weeks for the IRS to assign a number. The fastest

way to obtain an EIN is online at www.IRS.gov/ein. There are options to apply by fax or by mail, but applicants

are strongly encouraged to use online submission. For more information, search “How to Apply for an EIN”

on 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.

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

Due Date for LITC New Grant Applications and Continuation Requests

To be considered for 2027 LITC grant funding, grant applications must be submitted by 11:59 p.m. ET on July

6, 2026. The time and date of the email conﬁrmation from the LITC Grants Portal acknowledging application

submission serves as evidence that the application was timely submitted and should be retained by the applicant.

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 described 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.

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

E. BUDGET CONSIDERATIONS AND FUNDING RESTRICTIONS

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:

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);

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);

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

recipient. See 2 CFR § 200.403(c);

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);

Be determined in accordance with generally accepted accounting principles, except for state and local

governments and Indian tribes only, as otherwise provided for in the cost principles. See 2 CFR § 200.403(e);

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 );

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

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, the LITC Program Office may use discretion to waive

prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to 2 CFR

§ 200.308(g)(3).

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

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

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

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

Treasury, of which the IRS is a bureau, adopted the provisions in 2 CFR Part 2006 with specific exceptions 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.

See 2 CFR Part 1000.23.

LOW INCOME TAXPAYER CLINICS

BEST PRACTICE

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

funds. Several independent vendors offer 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. An applicant may 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. This is most

often the case when hiring cannot start until the award is made. The budget must be adjusted accordingly. 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, the funding 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.

Grant funds for the immediately succeeding grant year, however, 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 LITC expenditures. The lefthand column lists items that are an allowable use of

federal grant funds or matching funds, and the righthand 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.

LOW INCOME TAXPAYER CLINICS

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. See 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 are directly related to their work on the LITC

grant. See 2 CFR § 200.473.

Refreshments for employees. See 2 CFR § 200.445.

Pens, mugs, and other small items of memorabilia

for pro bono representatives working with the clinic,

provided the cost is reasonable and consistent

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

200.403.

Professional licensing fees for employees or

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

See 2 CFR § 200.445.

Printing and publication costs incurred for LITC

activities. See 2 CFR § 200.461.

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

promote LITC services to taxpayers or for the

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

(3) and 200.445.

A reasonably proportionate share of the cost of audit

services. See 2 CFR § 200.425.

Lobbyist registration fees. See 2 CFR § 200.75.

Publicity costs directly associated with the LITC

Program. See 2 CFR § 200.421.

Costs of goods or services for personal use

(as opposed to business use) of LITC staff.

See 2 CFR § 200.445.

Installation of telephone lines, including a toll-free

line, and video conferencing equipment necessary

to provide LITC services to taxpayers. See

2 CFR § 200.471.

Costs incurred outside the performance period of

the award, unless specifically excepted by the LITC

Program Office. See 2 CFR § 200.420.

Travel performed by LITC staff and volunteers to

conduct LITC business. See 2 CFR § 200.475.

Application and other related fees associated with

entry into the profession for an attorney, CPA, or

enrolled agent. See 2 CFR § 200.445.

Travel costs 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.

LOW INCOME TAXPAYER CLINICS

Allowable Expenses

Unallowable Expenses

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).7

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:

[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.

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.

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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:

Salaries and wages of administrative and support staff;

Related employee beneﬁts;

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

Ofﬁce supplies; and

Legal and auditing charges.

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

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

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

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

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

15%. See 2 CFR §§ 200.414(c), 200.414(f ).

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

Negotiated Indirect Cost Rate Agreements and Cognizant Agencies

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

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

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

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

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

assigned to HHS or the Department of Defense (DoD) Ofﬁce of Naval Research, normally 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

LOW INCOME TAXPAYER CLINICS

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-J, Detailed Budget Worksheet and Narrative

Explanations.

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 up to 15% 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% de minimis indirect cost rate. However, if the

clinic elects to use the de minimis rate to charge indirect costs, it must charge costs consistently across federal grants

and may not double charge or inconsistently charge as both.

Modified Total Direct Cost

MTDC includes, among other things, all direct salaries and wages, applicable fringe beneﬁts, materials and supplies,

services, and travel. MTDC excludes certain items, including 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.

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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 thirdparty in-kind, can be accepted as matching funds when such contributions are:

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

Not used as a match or contribution for any other federal award. See 2 CFR § 200.306(b)(2);

Necessary and reasonable for accomplishment of LITC Program objectives. See 2 CFR § 200.306(b)(3);

Allowable under the applicable cost principles. See 2 CFR § 200.306(b)(4);

Not paid by the federal government under another award, except when authorized by federal statute. See

2 CFR § 200.306(B)(5);

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

In conformity with other applicable provisions of the Uniform Guidance. See 2 CFR § 200.306(b)(7).

Qualiﬁed matching funds can be from multiple sources and include cash, volunteer services, property, and income

from program activities. Third-party in-kind contributions, defined in 2 CFR § 200.1, are the value of non-cash

contributions such as property or services, that (a) benefit a project or program funded by a federal award and (b)

are contributed by non-federal third parties, without charge, to a non-federal entity under a federal award. Grants

may be awarded based on good faith estimates of matching funds, including veriﬁable pledge commitments or other

likely sources of funding. However, grant recipients are advised to monitor the sources and uses of matching funds

throughout the grant year to ensure that sufﬁcient matching funds are available to meet the dollar-for-dollar match

requirement in IRC § 7526(c)(5). Failure to document the sources and amounts of all matching funds may result in

the LITC Program Ofﬁce requiring the grant recipient to repay federal funds (plus any applicable interest) received

in excess of the documented match. Failure to repay the funds within 90 days after the demand results in a debt to

the federal government that can be collected by the IRS in accordance with 2 CFR § 200.346.

LOW INCOME TAXPAYER CLINICS

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 market 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,

such as 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:

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

Fair market value. See 2 CFR § 200.404(c).

Non-cash contributions, such as goods, space, or volunteer services donated to the LITC, from parties other than

the grant recipient or the federal government (i.e., third-party in-kind contributions) must be valued in accordance

with the principles stated in 2 CFR § 200.306 (except for contributions of certain volunteer services by a qualiﬁed

representative governed by 2 CFR § 1000.306).

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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, such as a local law ﬁrm’s pro bono program, 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 provided

ten hours of volunteer service from an associate attorney in its tax division to an LITC, the LITC could value those

ten hours at the attorney’s regular rate of pay at the law ﬁrm plus reasonable fringe beneﬁts, provided the attorney

performs ten hours of substantive legal work. See 2 CFR § 200.306(f ).

Valuation Depends on the Type of Services

Grant recipients should also be mindful that a volunteer may meet the deﬁnition of a qualiﬁed representative yet

may be providing services to the clinic in a non-representative capacity. In the previous example, if the attorney

spent ten hours repainting the lobby of the LITC over a weekend instead of performing legal work, the LITC could

still count the volunteer’s time as matching funds; however, it would need to value the attorney’s time at the rate for

hiring a painter in the local labor market plus reasonable fringe beneﬁts.

Services Donated by Employees May Not Be Used as Matching Contributions

An employee of the grant recipient may not be treated as a volunteer for purposes of valuing in-kind services.

For example, suppose an LITC pays an employee an hourly wage to work at the LITC three days a week, and the

employee spends an additional two days each week volunteering at the LITC. In the example, the LITC may charge

the employee’s wages as an expenditure of federal or matching funds, but it cannot apply the value of the two days

spent volunteering as a contribution to help meet the matching funds requirement.

Special Rule for Valuing Volunteer Services of a Qualified Representative

When the Treasury Department implemented the cost principles of 2 CFR § 200.306, it provided that

notwithstanding the general rule prescribed in § 200.306(e), LITCs may use the rate found in IRC § 7430 to value

volunteer in-kind services, if the following conditions are met:8

The grant recipient is funded to provide controversy representation;

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;

The qualiﬁed representative is not a student; and

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

See 2 CFR § 1000.306.

LOW INCOME TAXPAYER CLINICS

IRC § 7430 are satisﬁed. The rate at which to value those services is adjusted periodically for inflation. For the 2026

calendar year, the maximum rate is $260 per hour, as prescribed in Revenue Procedure 2025-32, 2025-45 IRB 707

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

Use multiple sources of matching funds, such as state, local, private, and 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 the federal funds.

iv. Office of Management and Budget Audit Requirement

A grant recipient that expends $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 funds expended by the organization includes

all sources of federal funding, not just the funds received from the IRS to support the LITC. See 2 CFR § 200.502.

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 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:

Offers ﬁnancial statements that present fairly its ﬁnancial position and the results of its operations in

accordance with generally accepted accounting principles;

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

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.

LOW INCOME TAXPAYER CLINICS

APPLICATION AND SUBMISSION PROCESS

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 website at https://pms.psc.gov/grant-recipients/audit-confirmation-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

Applications that pass the eligibility screening process will then undergo a technical evaluation by a ranking panel.

Applications can receive a maximum of 100%. 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 application, the application will not move forward in the review process and will not receive an award.

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 supports the goals of the LITC Program. Returning

applicants must answer all the questions fully, keeping in mind that the ranking panel will not have access to any

information regarding the applicant’s past performance other than what is provided in the application. See Figure 5

for a percentage of points awarded to each section of the application.

Background

This section includes an overview of the sponsoring organization, years in operation, size, and service area; service

delivery currently being provided and selected data on service provision; and experience in service delivery whether

operating an LITC or delivering representation and education services to low-income and ESL taxpayers.

Taxpayer Access, Geographic Coverage, and Outreach

This section requests information about language access, language options, and reasonable accommodation. Because

the clinic must be able to effectively communicate with ESL taxpayers, the applicant must explain how they will

educate taxpayers about their rights and responsibilities or when representing them in controversies. This section also

requests information about provision of reasonable accommodation, geographic service area, and target audience,

including a requirement to cite the sources of data used to describe the service area. The applicant must list current

or planned partnerships and explain how those partnerships will be used to reach and deliver services to taxpayers.

The applicant must also explain how they plan to publicize the clinic and conduct outreach. If the clinic participates

in a U.S. Tax Court program, that should also be stated.

Taxpayer Services

The applicant should detail the approach that will be used to deliver each of the key clinic services for either an ESL

Education program or a program to provide Representation, Education, and Advocacy.

LOW INCOME TAXPAYER CLINICS

APPLICATION REVIEW

Staffing

The staffing section requests names and contact information for key personnel, along with their qualifications

and education. If a position has not yet been filled, the applicant should provide information about the education

or qualifications required for a successful job candidate. For programs providing representation, education, and

advocacy, if no staff member is licensed in U.S. Tax Court, the applicant will be asked about future plans to provide

services in U.S. Tax Court, if any. Alternatively, if a clinic will use a volunteer to provide services, the clinic is asked

to provide information about that volunteer. Lastly, the applicant should describe whether and how students will be

used to help deliver services.

Volunteers

This section addresses the use of volunteers, including a description of the clinic’s pro bono (volunteer) panel and

plans for volunteer recruiting and retention. Applicants should provide a robust explanation, especially if they plan

to rely upon volunteer services to help meet match requirements or to serve as a primary service delivery model.

Clinic Operations

This section will provide information about how services will be provided. The questions asked depend upon which

type of services the applicant is electing to provide: ESL Education or a Full LITC. For purposes of this section, if

the question only applies to full LITCs, “full” will be noted after the criteria.

Information requested includes:

Day, dates, and hours of operation;

Whether the clinic proposes to reduce the level of service for more than 30 consecutive days during a

grant period;

Intake process used for taxpayers to request services and for determination of eligibility, etc. (Full);

Policy on acceptance of cases over 250% of poverty level (Full);

Policy on acceptance of cases where the amount in controversy exceeds the general limit (Full);

Plans to charge a nominal fee (Full);

Case management system (Full);

Case assignment procedures (Full);

Monitoring procedures (Full);

Time tracking and procedures;

Security and privacy; and

Complaint procedures.

Training and Resources

The training and resources section is where the applicant demonstrates that it has a plan for ensuring that its staff

(including students and volunteers) are knowledgeable, current, and able to secure additional training when needed

to acquire additional skills to perform their work. Applicants should consider not only substantive tax law training

but training on administrative processes, procedures, and grant requirements. The applicant should differentiate

between internal and external training and list any available research materials and software available to the clinic.

LOW INCOME TAXPAYER CLINICS

Financial Responsibility

This section asks the applicant to describe its ability to properly spend and account for federal and matching funds

by explaining:

Experience managing federal grants or other state and private funds;

Accounting procedures;

Whether the clinic provides current year tax preparation (as this activity needs to be tracked separately for

grant purposes);

How grant expenditures other than time are identified and tracked;

Plans for financial audits or reviews;

Description of the financial statement provided with the application;

Whether it is audited or unaudited;

Whether the clinic is a recipient of Legal Services Corporation (LSC) funds; and

Date of financials submitted.

Program Evaluation and Improvement

In this section, the applicant should describe its approach to defining and measuring success and determining client

satisfaction. The applicant should also explain how it plans to use program evaluations to improve its services.

Program Numerical Goals

The applicant should describe its approach to setting goals and list the numeric goals for 2027.

Civil Rights Information

The responses to the Civil Rights Information section and the Reasonable Accommodation response earlier in

the application will be used by the Office of Civil Rights and Compliance to evaluate whether the applicant is

compliant, conditionally compliant, or non-compliant with civil rights laws. This section is not scored, but it

is mandatory.

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.

LOW INCOME TAXPAYER CLINICS

APPLICATION REVIEW

Figure 5, Grants Evaluation Breakdown of Scoring

Section

Full LITC Percent

ESL Education Percent

Background/Experience

10%

Financial Responsibility

10%

Taxpayer Access, Geographic Coverage, and

Outreach

13%

Taxpayer Services

10%

13%

Staffing

17%

14%

Volunteers

Clinic Operations

20%

Training and Resources

Program Eval and Improvement

Program Numerical Goals

B. LITC PROGRAM OFFICE EVALUATION AND SELECTION OF NEW

GRANT APPLICATIONS AND CONTINUATION REQUESTS

LITC Program Office Evaluation

New Grant Applications that earn a score of 50% 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, if applicable. The LITC Program Ofﬁce

will also review and evaluate Continuation Requests for progress on program delivery. LITC reviewing ofﬁcials are

subject to recusal if participation in an evaluation would cause a conflict of interest or the appearance of a conflict of

interest; in this circumstance, another staff member will be identified to conduct the review.

Evaluation of New Grant Applications

The LITC Program Ofﬁce will consider:

Quality of the proposed program;

History of performance under LITC grants in prior years, if applicable;

Soundness of the proposed budget; and

Any 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.

LOW INCOME TAXPAYER CLINICS

The proposed budget, any audit findings, and the applicant’s performance history in the LITC Program will be

considered in assessing the risk. The performance history includes:

Timeliness, accuracy, and completeness of Interim and Year-End reports;

Any significant concerns identified by the LITC Program Office and how the grant recipient addressed

those concerns;

Whether the grant recipient’s past activities match its program plan;

Whether the grant recipient has a history of not spending all the funds awarded; and

History of any failure(s) to deobligate unspent funds promptly.

If risks are identified, the Continuation Request will receive a new review. As a part of that review, the National

Taxpayer Advocate (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 2027.

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:

Existence of other clinics in the applicant’s geographic coverage area assisting the same population of taxpayers;

Scope of services that the clinic will provide;

The number of low-income and ESL taxpayers who will be assisted;

Languages in which assistance will be provided to taxpayers;

Reasonableness of funds sought for the quantity and quality of services to be offered;

Other sources of funding available to the clinic;

The sources of matching funds that the clinic plans to use;

Anticipated funding available to the LITC Program Office for grant awards;

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; and

All other factors being equal, which organization has a lower rate for indirect costs.

For organizations that are requesting federal funds to provide representation by referring taxpayers to qualified

representatives, award decisions will also consider:

The qualifications of the representatives who have agreed to accept pro bono case referrals from the LITC; and

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.

LOW INCOME TAXPAYER CLINICS

APPLICATION REVIEW

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:

Providing technical assistance;

Training and mentoring other LITCs;

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

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

Mentoring graduates and encouraging them to perform pro bono work on behalf of low-income and ESL

taxpayers.

All information supplied by the applicant may be verified by the LITC Program Office using additional sources,

including but not limited to the applicant’s website, websites providing accreditation information or licensure status,

state boards, or the Office of Professional Responsibility.

Final Funding Decision

Funding recommendations are made by the National Taxpayer Advocate and final approvals are secured from

Treasury, Assistant Secretary for Management (ASM), or Treasury ASM designee. In recusal situations where the

National Taxpayer Advocate has a potential or actual conflict of interest with an applicant, the Deputy National

Taxpayer Advocate shall assume the National Taxpayer Advocate’s role in making the funding recommendation for

that applicant.

ii. Civil Rights Compliance Reviews

All New Grant Applications that receive a ranking panel score of 50% 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

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:

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;

The population eligible to be assisted broken out by race, color, national origin, age, sex, or disability; and

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,

LOW INCOME TAXPAYER CLINICS

the LITC 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:

External building accessibility (e.g., accessible entrances, curb cuts, sufﬁcient parking spaces for persons with

disabilities);

Interior accessibility (e.g., signage for emergency routes, routes to and within the service area, sufﬁcient seating

in the service area, restrooms, water fountains, elevators);

Non-discrimination policies (e.g., Publication 4053, Your Civil Rights Are Protected, displayed in service areas;

the organization’s non-discrimination policy posted and disseminated in marketing materials); and

Accommodations for persons with disabilities (e.g., sign language interpreters; Braille/large print documents).

The results from the selected post-award reviews are compiled into a report and provided to the LITC

Program Ofﬁce.

LOW INCOME TAXPAYER CLINICS

Award Administration

VI. AWARD ADMINISTRATION

A. NOTIFICATION OF SELECTION

The LITC Program Ofﬁce will notify all applicants by November 2026 whether they have been selected to receive

a 2027 grant award. Selected applicants will first be notiﬁed by an LITC Grants Portal email directing them to log

into the portal where they can view the funding notification.

If Congress has passed ﬁnal appropriations legislation for the 2027 ﬁscal year by the time applicants are notified of

selection, the notiﬁcation of selection will include the final amount of the award. If Congress has not passed ﬁnal

appropriations legislation for the 2027 ﬁscal year by the time applicants are notified of selection, the notification

will indicate that the funding amount listed is dependent upon the passage of appropriations legislation. If the total

amount of appropriation or the award cap is reduced, the amount listed in the funding notification may be subject

to reduction. In addition to the funding amount, the notification may also include notations regarding needed

changes to the budget, or it may list special terms and conditions for the award.

An applicant can signal acceptance of the funding notification in the LITC Grants Portal by selecting “Start an

Application Amendment” or “Request a Conference” if the applicant has questions before proceeding. All applicants

that agree to the funding notification will be required to complete an application amendment to finalize the award.

After notiﬁcation of selection, the LITC 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 are also

required to send representatives to attend the Annual LITC Grantee Conference in-person, 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 by email. The applicant

may contact the LITC Program Office for information about the reasons for non-selection.

B. NOTICE OF AWARD

The LITC Program Ofﬁce will issue an NOA to each applicant selected to receive funding for the grant year. It will

contain 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 initial

NOA may be for less than the full amount of the anticipated award. The LITC Program Ofﬁce may then issue

subsequent NOAs, each providing an additional disbursement of funds.

The NOA will provide the amount of funding awarded to the grant recipient, whether the full or 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, where applicable.

All funding will be based on the availability of annually appropriated funds. If more funds become available during

the grant year, the LITC Program Ofﬁce may award additional funds to well-performing clinics not receiving

maximum funding. Receipt of additional funding will require an amended budget and issuance of a revised NOA.

The total award amount may not exceed the statutory cap unless otherwise legislated by Congress. Requests for

additional funds must be made in writing and timely submitted with the interim progress report 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

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

It is the policy of the LITC Program Office that LITCs providing representation services have a staff member or

volunteer who is admitted to practice before the U.S. Tax Court and other federal courts to represent taxpayers in

litigation matters. If an applicant does not have a staff member or a volunteer identified to provide these services at

this time, the applicant is asked to develop and submit a plan to do so. If the clinic does not have current plans to

provide this service, it may impact the award of funds or the amount awarded. 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 LITC 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 utilizing workshare space as a physical place of business, the workshare space must satisfy

the following criteria:

The clinic must be able to identify it as the clinic’s place of business in letterhead and correspondence.

The clinic must have access to a private office and private meeting space to enable confidential conduct

of business.

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.

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 LITC Program Ofﬁce encourages clinic staff and volunteers to attend

continuing professional education programs sponsored by the IRS and professional organizations with expertise in

tax law and tax controversy resolution relevant to low-income and ESL taxpayers. 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) training for staff and volunteers. Clinic training is reported on Form 13424-R under the Clinic

Information section.

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

LOW INCOME TAXPAYER CLINICS

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 activity highlighted in the

webinar. The LITC 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 conducts yearly webinars to provide potential applicants with information about the

application requirements and process. The intended audience for the webinars includes applicants proposing to start

an LITC or expand the work of existing clinical programs.

Join the LITC Program Office for optional webinars to learn more about the LITC Program and the application

process. Details are available at www.taxpayeradvocate.irs.gov/about-us/litc-grants. A separate webinar for Returning

applicants (New and Continuation Requests) will be announced on 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 LITC Program Ofﬁce will also

announce webinars on tax-related topics sponsored by other organizations such as the IRS and 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, it 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 LITC Program Ofﬁce giving any preferential or negative treatment to the LITC. The

LITC Program Ofﬁce is merely informing LITCs of training opportunities that may be of interest to clinicians.

iii. Annual Low Income Taxpayer Clinic Grantee Conference

Applicants notiﬁed they have been selected to receive a 2027 grant award must attend the Annual LITC Grantee

Conference, which is anticipated to be held in December 2026. 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 LITC 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, 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

LOW INCOME TAXPAYER CLINICS

Award Administration

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 generally 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 their designee will grant approval to timely submitted requests for additional registrants if space is available. If the

grant recipient seeks to use LITC grant or matching funds to support a third attendee, the request must explain the

special circumstances and include the estimated costs. 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, 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 exception requests 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.

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 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,

free newspaper listings, public service announcements on radio and television, websites, and social media. If a

clinic wants to use grant funds for paid advertising, it must request permission to use grant funds for this purpose

and explain why free publicity by itself will not be effective in reaching taxpayers. 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 taxpayers’ needs and how taxpayers can easily locate information about the clinic

LOW INCOME TAXPAYER CLINICS

and its services. Paid advertisements must receive advance written approval by the LITC Program Office and should

be detailed in the budget submitted.

Publicity materials and announcements to promote LITC services must focus on core services:

Representation in controversy cases;

Consultations about tax matters;

Education about taxpayer rights and responsibilities; and

Advocacy efforts to resolve systemic tax issues that affect low-income and ESL taxpayers.

Grant recipients are encouraged to publicize their program through their organization’s website,

social networking platforms, and community partners.

Publicity materials may not promote 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.

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 on their websites. High quality electronic files of the logo are available on

the LITC Toolkit. The logo should not be altered.

With the passage of the Taxpayer First Act, Section 1402,9 IRS employees can refer a taxpayer to a speciﬁc LITC for

assistance without violating the applicable ethical standards of conduct. Before the change in law, IRS employees

were prohibited from referring a taxpayer to a particular LITC practitioner or a speciﬁc LITC for assistance with

an IRS issue. All IRS Taxpayer Assistance Center (TAC) locations are annually provided with copies of Publication

4134, Low Income Taxpayer Clinic List, to facilitate these referrals. In addition, Section 1401 of the Taxpayer

First Act promotes collaboration between LITCs and Volunteer Income Tax Assistance (VITA) grant recipients by

encouraging VITA grant recipients to advise taxpayers about the availability of LITCs, the eligibility requirements

for assistance, and the locations and contact information for the clinics.

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

LOW INCOME TAXPAYER CLINICS

Award Administration

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 LITC 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 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.

BEST PRACTICE

A regular schedule for updating staff within the sponsoring organization can be very helpful. 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 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 also 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.

LOW INCOME TAXPAYER CLINICS

viii. Technical Assistance

Technical assistance is a discussion with a tax practitioner or other service provider designed to provide brief advice

about a federal tax issue. This assistance may 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 staff member of the

clinician’s sponsoring or colocated organization to provide to a client about a speciﬁc tax issue, it is probably more

properly counted as a taxpayer consultation, not a technical consultation. Grant recipients may report the number

of technical assistance consultations provided under the Advocacy section on Form 13424-R, Low Income Taxpayer

Clinic (LITC) Program Report.

ix. Maintaining Client Confidentiality

Avoiding Unauthorized Disclosure

Tax professionals have ethical requirements to maintain client conﬁdentiality.10 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 must safeguard taxpayer information against inadvertent or unauthorized disclosure. Thus,

it is critical for an LITC to maintain strong 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.11 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. If using a taxpayer’s situation as an example or case study in the training, the material facts must 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.

See, for example, ABA Model Rule of Professional Responsibility 1.6, IRC § 7525, and IRS Circular 230.

See 26 CFR § 301.7216-2.

LOW INCOME TAXPAYER CLINICS

Award Administration

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 they 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.

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. These may include whether the volunteer may act as an authorized representative, prior 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 use 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, except 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.

LOW INCOME TAXPAYER CLINICS

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. If a clinic provides representation primarily through referral, the clinic is encouraged to track cases placed with

other LITCs or placed with volunteers on behalf of other LITCs. A future revision of Forms 13424-M and 13424-R

is planned which will enable clinics using this service delivery model to set goals and report numbers for these types

of referrals.

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 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:

Which individuals have approval authority;

When written approval is required; and

What documentation must be submitted for an expense to be approved by the authorized ofﬁcial.

The approval process may differ based on the size and type of expense. Also, LITCs must have written procedures

to track their ﬁxed assets and tangible personal property. To avoid subsequent disallowance or dispute based on

unreasonableness or non-allocability of an expense, the grant recipient may seek the prior written approval from

the LITC Program Ofﬁce in advance of incurring special or unusual costs. Prior written approval should include

the timeframe or scope of the proposed cost. The absence of prior written approval of any element of cost will

not affect the reasonableness or allocability of that element, unless prior written approval is speciﬁcally referenced

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

LOW INCOME TAXPAYER CLINICS

Award Administration

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:

Identify the date on which the services were performed;

Describe the nature of those services in detail;

Identify the individual’s name and position of any representative for whom fees are claimed (e.g., supervisory

attorney, student, paralegal); and

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:

Initial client interview;

Research (identifying issues);

Preparation of pleadings or other court documents;

Preparation of letters (identifying the recipient and subject matter);

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

Analysis of taxpayer or third-party records (identifying the records);

Consultation with tax return preparer (identifying the preparer);

Consultation or interview of third party (identifying the person); or

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 IRB 436.

Using a Professional Case Management System

Grant recipients are expected to use a case ma

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