IRS Form 13424-F Guide: Volunteer Pro Bono Time Reporting

1. Introduction: What is Form 13424-F?

IRS Form 13424-F, officially titled Volunteer / Pro Bono Time Reporting, is an administrative grant compliance worksheet issued 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 tax laws.

Unlike standard tax returns filed by wage earners or businesses, Form 13424-F is a specialized recordkeeping tool used within the Low Income Taxpayer Clinic (LITC) program. The program is administered independently by the Taxpayer Advocate Service (TAS) through the national LITC Program Office.

Under Section 7526 of the Internal Revenue Code, the federal government provides matching grants to qualifying non-profit legal clinics and universities that represent low-income taxpayers. Form 13424-F allows clinics and volunteer tax professionals—such as pro bono attorneys, Certified Public Accountants (CPAs), and Enrolled Agents (EAs)—to log and verify volunteer hours worked on tax controversy cases.

2. Purpose of the Form

Federal law requires every organization receiving an LITC grant to match each dollar of federal funding with at least one dollar of non-federal matching funds. While clinics raise part of this match through cash donations or foundation grants, many rely heavily on “third-party in-kind contributions”—specifically the donated professional time of volunteer attorneys, accountants, and advocates.

Under federal grant accounting rules established in Title 2 of the Code of Federal Regulations, in-kind volunteer contributions must be verifiable through clear, contemporaneous records. The IRS cannot accept broad estimates or unverified claims of pro bono work when evaluating a clinic’s financial match.

Form 13424-F solves this compliance challenge by providing an approved, standardized format for tracking volunteer time. By documenting exactly who performed the work, the dates of service, the specific client case involved, and the substantive tasks completed, the form creates the verifiable audit trail needed to substantiate in-kind matching funds.

3. Who Needs to File This Form

Form 13424-F is not filed by everyday taxpayers. Instead, it is used by individuals and organizations participating in the LITC pro bono service network, including:

• Pro Bono Panel Attorneys: Private practitioners who volunteer their legal services to represent low-income taxpayers referred by an LITC.
• Volunteer CPAs and Enrolled Agents: Licensed tax professionals who donate their time to negotiate with the IRS, prepare controversy filings, or review client audit files.
• Community Volunteers and Interpreters: Volunteers who provide bilingual translation, intake assistance, or client coordination support for an LITC.
• LITC Administrators: Clinic Directors and Qualified Business Administrators (QBAs) who collect, verify, and retain time logs to support their matching fund calculations on annual grant reports.

4. Who Is Exempt / Not Required to File

Because Form 13424-F is an internal recordkeeping tool tailored specifically to LITC matching fund compliance, most taxpayers and volunteers do not use it:

• Individual Taxpayers: Low-income clients represented by a clinic or pro bono attorney never complete or sign this form.
• Paid Clinic Staff: Regular employees who receive a salary or hourly wage from the clinic cannot report their hours on Form 13424-F, as their compensation is already accounted for as direct grant expenditures.
• Students Receiving Academic Credit: Law, business, or accounting students who participate in a clinic for academic course credit are strictly prohibited under IRS Publication 3319 rules from having their time counted as in-kind matching contributions.
• VITA and TCE Volunteers: Volunteer preparers working at free tax preparation sites use Form 13206 and Form 13615 under the IRS SPEC partnership program, not LITC forms.
• Commercial Tax Preparers: For-profit practitioners operating private practices without an affiliation to an approved LITC do not use this worksheet.

5. When to File

Form 13424-F operates on a continuous, contemporaneous tracking schedule rather than a fixed annual filing deadline:

• Contemporaneous Recording: Volunteers should record their time on Form 13424-F in real time as tasks are performed, or at least on a weekly basis, rather than trying to reconstruct hours months later.
• Periodic Submission to the Clinic: Pro bono practitioners typically submit completed forms to their clinic coordinator on a monthly or quarterly basis, or immediately upon the closing of a referred client’s case.
• Internal Retention: Form 13424-F is an internal recordkeeping document. The clinic retains completed forms on file and submits them to the IRS only when requested during an official on-site operational review, orientation visit, or financial compliance audit.

6. Where and How to File

Form 13424-F is not filed through standard electronic tax return systems. It is managed directly between the volunteer practitioner and the sponsoring LITC organization.

Volunteers complete the form and deliver it to their local clinic coordinator via email, secure file upload, or physical mail. Many modern clinics use legal case management software (such as LegalServer) that incorporates electronic versions of Form 13424-F, allowing volunteers to log their time online directly into the client’s file.

When the LITC Program Office conducts an operational review or financial sampling, the clinic administrator must make these completed forms available for inspection. If the IRS requests hard-copy proof of matching funds by mail, clinics send records to the specific IRS address as per instructions provided by their assigned LITC grant analyst.

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

Form 13424-F is a concise worksheet designed to capture clear details about the volunteer and the nature of their services. Review the table below for a line-by-line guide to completing the form.

Section Name	Required Information	Instructions for Volunteers
Volunteer Information	Full Name & Title	Enter your legal name, contact details, firm name, and professional credentials (Attorney, CPA, EA, or Other).
Activity Date	Date of Service	Record the specific date (MM/DD/YYYY) on which the professional activity took place.
Case Identification	Case ID / Client Number	Enter the internal case number assigned by the clinic; do not use the taxpayer’s Social Security Number.
Consultation Time	Client Meetings & Calls	Record hours spent meeting with the client in person, over the phone, or via virtual conference.
Case File Review	Document Analysis	Log time spent reviewing IRS notices, prior-year tax returns, financial statements, and client records.
Legal & Tax Research	Substantive Research	Track hours dedicated to analyzing tax code sections, Treasury regulations, court decisions, and IRS manuals.
IRS Communications	Advocacy & Negotiation	Record time spent communicating with IRS examiners, revenue officers, Appeals officers, or Chief Counsel attorneys.
Document Drafting	Drafting Petitions & Forms	Log time spent preparing U.S. Tax Court petitions, protest letters, Offers in Compromise, or penalty abatement requests.
Hearings & Conferences	Appearances & Trials	Record time spent attending IRS Appeals conferences, Collection Due Process hearings, or Tax Court calendar calls.
Certification & Signature	Volunteer Signature & Date	Sign and date the form to certify that the recorded hours are true, correct, and represent unpaid volunteer service.

Valuation of Volunteer Hours

When clinics translate reported volunteer hours into in-kind matching dollars on their grant expenditure reports, they must establish a reasonable hourly rate. Use these basic principles:

• Reasonable Market Value: The hourly rate claimed for pro bono attorney or accountant time must reflect the prevailing market rate for similar legal or accounting services within that geographic area.
• Service-Based Valuation: Time must be valued according to the nature of the service provided, not merely the volunteer’s regular billing rate. For example, if an attorney performs general administrative filing, that time must be valued at an administrative rate, not an attorney rate.
• Written Justification: The clinic must maintain documentation justifying the hourly valuation schedule used, such as regional bar association economic surveys or local market rate studies.

8. Required Documents/Information Needed Before Filling

Before completing Form 13424-F, volunteers and clinic coordinators should have the following records on hand:

• Clinic Case Number: The unique client identification number assigned by the LITC to maintain client confidentiality under privacy laws.
• Detailed Time Logs: Daily calendar entries or billing software printouts showing exact start and stop times or tenths-of-an-hour increments.
• Form 2848 (Power of Attorney): A copy of the active authorization on file with the IRS confirming the volunteer is authorized to represent the taxpayer.
• Volunteer Retainer Agreement: The signed pro bono agreement between the client, volunteer practitioner, and clinic outlining the scope of representation.
• Rate Justification Workpapers: Clinic records confirming the approved hourly valuation rate applicable to the volunteer’s professional discipline.

9. Common Mistakes to Avoid

Failing to maintain accurate volunteer records can create serious compliance problems during an IRS operational review. Avoid these common mistakes:

• Reporting Student Hours for Credit: Never log hours for law or business students who are receiving academic course credit for their clinic participation. This violates Publication 3319 rules and will result in disallowed matching funds.
• Reconstructing Hours from Memory: Waiting months to estimate volunteer time is unacceptable during a grant audit. All time logs must be maintained contemporaneously.
• Including Paid Staff Time: Time worked by salaried clinic personnel or contracted staff cannot be logged on Form 13424-F as in-kind volunteer contributions.
• Claiming Excessive Billing Rates: Using inflated private billing rates that far exceed prevailing community rates for non-profit legal services will trigger audit disallowances.
• Submitting the Form with Regular Grant Reports: Form 13424-F is an internal record. Uploading stacks of time sheets with your semi-annual narrative reports creates administrative confusion; keep them in clinic archives unless specifically requested.

10. Penalties for Non-Filing or Errors

Because Form 13424-F is an internal grant documentation worksheet rather than an individual tax return, there are no civil tax penalties or personal fines for failing to complete it. However, the federal grant consequences for the sponsoring organization are significant:

• Disallowance of In-Kind Matching Funds: If the clinic cannot produce signed, contemporaneous time logs during an audit, the IRS will reject the claimed volunteer matching funds.
• Grant Recoupment (Clawback): If disallowed volunteer hours cause the clinic’s total matching funds to fall below the mandatory dollar-for-dollar requirement, the organization must repay a corresponding portion of its federal grant award.
• Administrative Probation: Inadequate timekeeping systems can result in the clinic being placed on a formal Corrective Action Plan, increasing reporting oversight.
• Loss of Multi-Year Funding: Persistent recordkeeping failures can lead to premature cancellation of multi-year grant agreements and disqualify the clinic from future federal awards.
• False Claims Act Sanctions: Intentionally fabricating volunteer hours or forging signatures on federal grant documentation violates 18 U.S.C. Section 1001, exposing individuals and organizations to federal prosecution and civil fraud liability.

11. Related Forms or Schedules

Form 13424-F functions within a comprehensive family of LITC grant management forms and IRS publications:

• Form 13424: Low Income Taxpayer Clinic (LITC) Application Information
• Form 13424-A: Low Income Taxpayer Clinic (LITC) General Information Report
• Form 13424-B: Low Income Taxpayer Clinic (LITC) Case Issues Report
• Form 13424-C: Low Income Taxpayer Clinic (LITC) Advocacy Information Report
• Form 13424-J: Detailed Budget Worksheet
• Form 13424-K: Low Income Taxpayer Clinic (LITC) Case Information Report
• Form 13424-L: Statement of Grant Expenditures
• Form 13424-M: Low Income Taxpayer Clinic (LITC) Application Narrative
• Form 13424-N: Low Income Taxpayer Clinic (LITC) Program Narrative Report
• Form 2848: Power of Attorney and Declaration of Representative
• Publication 3319: Low Income Taxpayer Clinic Grant Application Package and Guidelines
• Publication 4134: Low Income Taxpayer Clinic List

12. Frequently Asked Questions

Do clinics routinely mail Form 13424-F to the IRS?

No. Form 13424-F is an internal recordkeeping tool that clinics maintain on site. It should only be provided to the IRS if requested to substantiate matching funds during an operational review visit, orientation visit, or financial compliance audit.

Can volunteer time spent on community outreach be reported on Form 13424-F?

Yes. If a volunteer attorney, CPA, or community advocate presents an educational workshop or conducts outreach to low-income or ESL taxpayers on behalf of the clinic, those volunteer hours can be logged on Form 13424-F as in-kind matching contributions.

Can an electronic case management database replace paper Form 13424-F sheets?

Yes. Many LITCs track volunteer hours using case management software such as LegalServer. As long as the digital system captures all the required data elements—including volunteer name, date, client reference, activity breakdown, hours, and volunteer verification—it serves as an acceptable substitute.

Can a volunteer log time spent traveling to a court hearing or IRS meeting?

Yes, provided the travel was necessary to deliver direct client representation or conduct approved clinic outreach, and the clinic’s written volunteer policy permits the inclusion of reasonable travel time.

Can law student volunteer hours ever be counted on Form 13424-F?

Law student hours may only be counted if the student is volunteering purely on an uncompensated, pro bono basis without receiving any academic course credit, fellowship stipend, or clinic wages. If the student receives academic credit, their time cannot be counted as an in-kind match.

How long must an LITC keep completed Form 13424-F records on file?

Under federal grant guidelines, clinics must retain all financial and timekeeping records for at least three years from the date the final expenditure report is submitted for that grant year. If an audit or review is underway, records must be retained until all findings are formally resolved.

13. Conclusion: Key Takeaways Summarized

IRS Form 13424-F is a critical tool for preserving federal grant compliance within the Low Income Taxpayer Clinic network. Keep these fundamental principles in mind:

• Substantiates Matching Funds: Form 13424-F provides the contemporaneous documentation needed to prove volunteer in-kind contributions for federal dollar-for-dollar matching requirements.
• Strictly for Unpaid Volunteers: Never report time worked by paid clinic staff or students receiving academic course credit.
• Log Time Contemporaneously: Record volunteer hours in real time with specific task descriptions and case numbers rather than estimating time months later.
• Internal Retention: Keep completed worksheets in clinic archives for at least three years, and submit them to the specific IRS address as per instructions only when requested during an operational review or audit.