IRS Form 13424-Q Guide: Student Practice Information Chart

1. Introduction: What is Form 13424-Q?

IRS Form 13424-Q, officially titled the LITC or STCP Student and Law Graduate Information Chart, is an administrative credentialing roster published by the Internal Revenue Service (IRS). The IRS is a bureau of the United States Department of the Treasury responsible for administering the federal tax code and enforcing professional tax practice standards.

Rather than reporting personal taxes or calculating corporate liabilities, Form 13424-Q is used in clinical legal education and pro bono tax controversy programs. The form is administered independently by the Taxpayer Advocate Service (TAS) through the national Low Income Taxpayer Clinic (LITC) Program Office.

Under Section 10.7(d) of Treasury Department Circular No. 230 and Delegation Order 25-18, the IRS allows qualifying students and recent law graduates to represent taxpayers before the agency under direct supervision. Form 13424-Q serves as the official itemized roster submitted by clinics to identify each individual student or graduate seeking this special appearance authority.

2. Purpose of the Form

Federal tax regulations strictly restrict “practice before the IRS” to licensed attorneys, Certified Public Accountants (CPAs), and Enrolled Agents (EAs). Uncredentialed individuals—such as law students, business majors, or unadmitted law graduates—are legally prohibited from speaking with IRS examiners, negotiating debt settlements, or inspecting client transcripts.

However, academic tax clinics and legal aid societies depend on student practitioners to deliver free representation to vulnerable, low-income taxpayers. These clinical experiences provide students with invaluable practical skills while expanding legal access for taxpayers who cannot afford private counsel.

Form 13424-Q works in tandem with Form 13424-P (Application for Special Appearance Authorization) to solve this regulatory hurdle. While Form 13424-P acts as the clinic’s formal application, Form 13424-Q provides the itemized student roster. It verifies each participant’s academic enrollment, degree program, prerequisite coursework, and assigned supervising attorney so the IRS can issue an official Special Appearance Authorization letter.

3. Who Needs to File This Form

Form 13424-Q is an institutional roster document submitted by clinic directors and supervising practitioners rather than individual students. You need to complete and file this form if you hold either of the following roles:

• LITC Clinic Directors & Supervisors: Leaders of federally funded Low Income Taxpayer Clinics at law schools, business schools, or non-profit legal aid organizations who wish to authorize student interns and recent law graduates to handle IRS controversy casework.
• Student Tax Clinic Program (STCP) Directors: Faculty supervisors at non-funded academic tax clinics operating within accredited universities that meet IRS clinical standards and desire special appearance authority for enrolled students.

The form is completed by the lead supervising practitioner on behalf of the entire cohort of clinic participants. Individual students and graduates do not file this form independently.

4. Who Is Exempt / Not Required to File

Because Form 13424-Q is designed specifically for student clinical practice before the IRS, most practitioners and organizations never interact with it:

• Licensed Practitioners: Active attorneys, CPAs, and Enrolled Agents already possess full representation rights under Circular 230 Section 10.3 and are never listed on this chart.
• Individual Taxpayers: Low-income clients represented by clinic students do not complete or sign this roster document.
• Admitted Law Graduates: Law graduates who have already passed the bar exam and been formally admitted to practice law represent taxpayers as licensed attorneys on Form 2848.
• Volunteer Tax Preparation Programs (VITA/TCE): Volunteers working at Volunteer Income Tax Assistance or Tax Counseling for the Elderly sites prepare returns and do not engage in Circular 230 controversy representation, making special appearance rosters unnecessary.
• Clinics Without Student Representatives: Legal aid programs where all client advocacy before the IRS is conducted exclusively by licensed staff attorneys or CPAs.

5. When to File

Form 13424-Q operates on an academic-term or grant-year schedule rather than an annual tax filing calendar:

• Prior to Academic Semesters: Clinics typically submit Form 13424-Q several weeks before the start of each semester (Fall, Spring, or Summer) to ensure students receive authorization before clinic casework begins.
• Prior to Case Representation: Form 13424-Q must be submitted, reviewed, and approved by the LITC Program Office before any student contacts an IRS examiner, attends an Appeals conference, or executes Form 2848.
• Mid-Semester Updates: If new students, research fellows, or law graduates join the clinic mid-term, an updated Form 13424-Q must be submitted to add them to the clinic’s authorization list.

Authorizations are granted for a specified term, typically aligning with the academic calendar or grant year. Clinics must submit updated charts for each new semester or academic cohort.

6. Where and How to File

Form 13424-Q cannot be submitted through consumer tax preparation software or standard IRS public filing portals. It must be delivered through specialized administrative channels directly to the LITC Program Office.

Clinics submit Form 13424-Q as an attachment to Form 13424-P (Application for Special Appearance Authorization). The completed forms are typically transmitted electronically through the online LITC Grants Portal, by secure password-protected email, or by dedicated agency fax as directed in IRS Publication 3319.

If instructed to send hard-copy documentation, student transcripts, or supervisor license verifications by mail, deliver materials to the specific IRS address as per instructions in Publication 3319. Once approved, the LITC Program Office issues a formal authorization letter listing the approved individuals, which must be retained on file at the clinic.

7. Step-by-Step Instructions to Fill the Form

Form 13424-Q is structured as a multi-column roster chart designed to capture specific demographic, academic, and supervisory data for each student applicant. Review the table below for a column-by-column guide.

Column Item	Required Information	Instructions for Clinic Directors
Header	Clinic & Term Identification	Enter the official clinic name, sponsoring institution, LITC grant number (or STCP ID), and the applicable academic term.
Participant Name	Full Legal Name	Enter the student’s or law graduate’s full legal name (Last, First, Middle Initial) exactly as it will appear on client powers of attorney.
Institution & Program	School & Degree Program	List the accredited college or university and the degree program (e.g., J.D., Tax LL.M., Master of Accounting, or B.S. in Accounting).
Academic Status	Student Classification	Indicate whether the participant is a 2L law student, 3L law student, graduate student, undergraduate, or unadmitted law graduate.
Graduation Date	Expected / Actual Date	Enter the anticipated graduation date (Month/Year), or the actual graduation date for unadmitted law graduates.
Assigned Supervisor	Lead Practitioner & CAF Number	List the name and Centralized Authorization File (CAF) number of the licensed attorney or CPA directly supervising the student.
Prerequisites	Tax Coursework Confirmation	Confirm that the student has completed basic federal income taxation, clinic orientation, and ethics/confidentiality training.
Bar Attestation	Law Graduate Status	For law graduates, certify that the individual has not been admitted to any state bar and has never been denied admission on character or fitness grounds.

Understanding the Matching Rule for Form 2848

Accuracy on Form 13424-Q is essential because the names entered on this chart must match subsequent client filings. When an authorized student represents a taxpayer before the IRS, Form 2848 (Power of Attorney) is completed using these specific rules:

• Supervising Practitioner First: Line 2 of Form 2848 must list the lead supervising attorney or CPA first, followed by the student representative.
• Designation Code “k”: In Part II of Form 2848, the student enters designation code “k” (Qualifying Student), writes “LITC” or “STCP,” and signs the declaration.
• Attach Authorization Letter: A copy of the TAS Special Appearance Authorization letter—which lists the student’s name from Form 13424-Q—must be attached to Form 2848 when submitting it to the IRS Centralized Authorization File (CAF) unit.

8. Required Documents/Information Needed Before Filling

To ensure that Form 13424-Q can be completed accurately, compile the following source records prior to drafting the chart:

• Form 13424-P: The primary application form that must accompany Form 13424-Q.
• Student Enrollment Verifications: Registrar letters or law school rosters confirming active enrollment and expected graduation dates.
• Transcript or Coursework Records: Documentation verifying that each student completed prerequisite coursework in basic federal income tax.
• Supervisor License Records: Active bar numbers, CPA certificate details, and CAF numbers for all supervising practitioners.
• Law Graduate Attestation Letters: Written declarations from recent law graduates confirming their bar exam status and character-and-fitness standing.

9. Common Mistakes to Avoid

Procedural errors on Form 13424-Q can result in rejected authorizations or delays in casework. Avoid these frequent mistakes:

• Submitting Form 13424-Q Alone: Form 13424-Q is a supporting attachment. Submitting it without Form 13424-P will cause the LITC Program Office to return it unprocessed.
• Name Mismatches: Using a nickname or omitting a hyphenated surname on Form 13424-Q can cause the IRS CAF unit to reject client Form 2848 submissions. The name must match all legal documents.
• Listing Ineligible Graduates: Including a law graduate who has failed a moral character check or has been denied bar admission is strictly prohibited under IRS guidelines.
• Premature Client Contact: Allowing students to contact the IRS before the LITC Program Office issues the official approval letter constitutes unauthorized practice before the IRS.
• Overlooking the 130-Day CAF Purge: The IRS Centralized Authorization File (CAF) automatically deletes student representatives 130 days after Form 2848 is signed. If casework spans multiple semesters, a renewed Form 2848 must be submitted.

10. Penalties for Non-Filing or Errors

Because Form 13424-Q is an administrative credentialing roster rather than a tax return, failing to file does not trigger tax penalties or interest charges. However, the legal and professional consequences of unauthorized practice are severe:

• Rejection by the IRS: IRS examiners and Appeals officers will refuse to communicate with students who do not appear on an active Special Appearance Authorization letter.
• Sanctions for Supervising Practitioners: Licensed attorneys or CPAs who permit unauthorized students to represent taxpayers face investigation by the IRS Office of Professional Responsibility (OPR) for aiding unauthorized practice under Circular 230 Section 10.51.
• Disciplinary Action by State Bars: Supervising attorneys may face professional ethics discipline from their respective state bar associations for failing to properly supervise non-lawyer personnel.
• Grant Compliance Sanctions: LITC grant recipients that allow unauthorized representation risk losing their federal grant awards for non-compliance with Quality Site Requirements.
• False Statements Liability: Intentionally falsifying student enrollment, degree standing, or supervisor credentials on federal documents violates 18 U.S.C. Section 1001, carrying criminal fines and potential imprisonment.

11. Related Forms or Schedules

Form 13424-Q operates within a network of IRS clinical forms and professional practice regulations:

• Form 13424-P: Application for Special Appearance Authorization
• Form 2848: Power of Attorney and Declaration of Representative
• Form 8821: Tax Information Authorization
• Form 13424: Low Income Taxpayer Clinic (LITC) Application Information
• Form 13424-K: Low Income Taxpayer Clinic (LITC) Case Information Report
• Form 13424-M: Low Income Taxpayer Clinic (LITC) Application Narrative
• Publication 3319: Low Income Taxpayer Clinic Grant Application Package and Guidelines
• Treasury Department Circular No. 230: Regulations Governing Practice before the Internal Revenue Service

12. Frequently Asked Questions

How does Form 13424-Q differ from Form 13424-P?

Form 13424-P is the clinic director’s formal application and ethical attestation requesting special practice authority for the clinic. Form 13424-Q is the itemized roster chart that lists the specific names, degree programs, and assigned supervisors for all participating students and graduates.

Can undergraduate accounting students be included on Form 13424-Q?

Yes. Students enrolled in accredited undergraduate accounting or business programs can be listed on Form 13424-Q, provided they have completed basic federal tax coursework and work under the direct supervision of a licensed attorney, CPA, or Enrolled Agent.

How long is the authorization valid once Form 13424-Q is approved?

Authorizations generally align with the academic semester, term, or grant year specified on the form. Clinics submit updated charts for each new semester or when new student cohorts join the program.

What is the 130-day CAF expiration rule?

The IRS CAF computer system is programmed to automatically delete student authorizations (designation code “k”) 130 calendar days after the taxpayer signs Form 2848. This ensures that student access expires after an academic semester ends. If a student continues working on the case, a new Form 2848 must be executed.

Does being listed on Form 13424-Q permit a student to appear in U.S. Tax Court?

No. Form 13424-Q authorizes practice strictly before the Internal Revenue Service, which is an executive agency. Appearances before the United States Tax Court are governed separately under the Tax Court Rules of Practice and Procedure through student practice orders issued directly by the court.

What should a clinic do if a student leaves the clinic mid-semester?

If a student withdraws from the clinic or graduates early, the clinic director should notify the LITC Program Office and submit revocations on Form 2848 for any active client cases assigned to that student.

13. Conclusion: Key Takeaways Summarized

IRS Form 13424-Q is the critical roster tool that enables clinical law and business students to advocate legally before the IRS. Keeping your student information accurate preserves program compliance and protects student credentials. Remember these core takeaways:

• Itemized Student Roster: Form 13424-Q details the names, degree programs, and assigned supervisors for all students seeking special appearance authorization under Circular 230.
• Always Pair with Form 13424-P: Form 13424-Q must be submitted alongside the primary application form to be considered valid.
• Direct Supervision is Required: Every student must be paired with an active, licensed attorney or CPA who holds a valid Centralized Authorization File (CAF) number.
• Attach Authorization to Form 2848: Ensure a copy of the official TAS approval letter listing the student’s name is attached to every power of attorney filed with the IRS.
• Submit via Designated Channels: Deliver completed charts through the LITC Grants Portal or to the specific IRS address as per instructions in Publication 3319.