Q: I assisted an 18-year-old with her FAFSA. She reported on her FAFSA that she didn’t file taxes, but is now being asked by her college to submit an IRS Verification of Nonfiling Letter. I’ve never heard of this form before. How do I assist the student with submitting it?
A: The FAFSA now uses “prior-prior” year tax data, so for the 2018-2019 school year, 2016 taxes would be used. Many students do not file taxes because they have earned less than the standard deduction. Students applying for the 2018-2019 academic school year who did not file taxes may now be required to submit an IRS Verification of Non-Filing Letter. This letter confirms that the IRS has not received a federal income tax return from the individual. The Verification of Nonfiling Letter is not an indication that the person is not required to file a return, just that they did not file one.
To obtain an IRS Verification of NonFiling Letter, the student will need to request an IRS Tax Return Transcript. This can be a complicated process and many students will need assistance.
1. A student can request their transcript online at https://www.irs.gov/individuals/get-transcript. Through this website the student can either have their transcript sent to them online or via mail.
- To obtain a transcript online, the student must satisfy certain security requirements such as owning a cell phone with their name on the account and having a credit card, auto loan or mortgage in their name. These requirements may be difficult for many students to satisfy and therefore they may need to request their transcript be sent to them via mail.
- To have the transcript mailed via the online tool, it will take 5-10 days to receive the tax transcript. Generally, there will be no address on file with the IRS if the student has never filed taxes. In this case, the letter will be mailed to the current address they provide. However, the IRS may already have the student’s address in their system, such as from W-2 or 1099 statements or a prior tax return. In this case, the mailing address on the form must match the address on file with the IRS. If the student’s current mailing address does not match the address on file with the IRS, the student should first file IRS Form 8822 to change their address, which will take approximately 10 days.
- Students may also call the IRS automated phone transcript service at 800-908-9946 to order a tax return or tax account transcript to be sent by mail.
2. Alternately, the student can complete IRS Form 4506-T on paper, check box 7 and send this form by mail or fax. On line 5 of IRS Form 4506-T the student can specify that the Verification of Nonfiling Letter be sent to a third-party address. In most cases the student should have it sent to themselves, not directly to the college. However, it is best to ask each college what they prefer. If a student submits this paper form by mail, it will take 7-14 days to be processed.
Note that there is no fee for obtaining the Verification of Nonfiling Letter or a tax transcript. If the student says there is a $50 fee, they are filing the wrong form. The form that is required is IRS Form 4506-T, not IRS Form 4506.