Step-by-step 8867 Due Diligence Notes (template)
1. What’s being claimed (scope)“Return claims: [EITC] [CTC/ODC] [AOTC] [HOH]. 8867 completed and filed with return.” 2. Identity & relationship check “Verified taxpayer/dep(s) identity & relationship. Docs reviewed (if relied upon): [SS card(s)], [birth cert], [court/guardianship], [school/medical records], [lease].” (Form 8867 allows you to list documents relied upon; none are specifically required unless facts trigger questions.) 3. Residency & household composition “Confirmed where each person lived and months in home; noted any temporary absences. Identified qualifying person(s) (if HOH) and confirmed tie-breaker not applicable.” (Knowledge requirement: ask adequate questions; document answers.) 4. Filing status (HOH if claimed) “Computed ‘cost of keeping up a home’ and confirmed taxpayer paid > 50%. Saved worksheet in file.” (Worksheets/computations must be retained.) 5. Income reasonableness “Matched income items to source docs; reconciled any gaps. If SE income, confirmed bona fide business activity; assisted with reasonable reconstruction when records incomplete.” (Reasonable follow-ups required when info is incomplete/inconsistent.) 6. Credit-specific tests • EITC — Verified age/relationship/residency; filing status not MFS; no disqualifying investment income issue based on info provided. • CTC/ODC — Verified age/SSN and support; identified which children qualify for CTC vs ODC. • AOTC — Reviewed 1098-T & billing; at least half-time; no 5th year; no felony drug conviction based on taxpayer statement; calculated QHEE net of tax-free aid. “Saved credit worksheets (EITC, Sch 8812/CTC, Form 8863/AOTC).” (You must keep applicable worksheets.) 7. Reasonable inquiries (red-flags addressed) “Documented follow-up Q&A wherever facts were inconsistent/incomplete. Recorded who provided each answer and when.” (Knowledge + record keeping requirements.) 8. Documents relied upon (8867 line 5) “Relied upon and listed on 8867: [W-2(s)], [1098-T/bursar stmt], [school/medical mail showing address], [lease/utility bills], [child-care statements], etc.” (Line 5 lets you list the docs you relied on.)