Yes, the client may claim the AOTC (provided he/she is otherwise eligible to claim the credit) if he/she requested a Form 1098-T from the college after January 31, 2025, and cooperated with the college to obtain necessary information to provide the Form 1098-T. You should advise your client to keep documentation of the communication with the college requesting the Form 1098-T. You should also satisfy the due diligence requirements by verifying and documenting your verification that the student is eligible to claim the AOTC, including verifying enrollment at an eligible educational institution and substantiating the payment of the qualified educational expenses during the year.
Remember: Record any additional questions you ask and your client’s answers at the time of the interview and keep copies of any documents your client does provide if you relied on them to determine if they qualify for or to compute the amount of the credit.
As a service to your client, a best practice is to advise your client to keep copies of these documents that establish his/her eligibility for the credit to provide to the IRS if they are audited.
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