HI Dave,
There is no exception for dual credit students. I realize they may not be 18 yet but they should still have an SSN in most cases. The W-9 would be the correct tool to collect this information and as you said, to qualfiy for the safe harbor to avoid insitutional penalties, you have to make a request at least once (at least twice is considered best practice).
Also, according to FERPA and federal guidelines, a student is considered an "adult" once they enter higher education.They could be 14 and you would still need to treat them independent from their parents, unless the parents provide their tax return showing the student as a dependent.I am not a FERPA expert so please be sure to consult with your institutional experts on the actual regulations.
And finally, my own $.02, the American Opportunity Tax Credit (AOTC) is the most beneficial educational credit since it can be refundable. However, there are limits that the student must be an undergraduate, at least half-time enrolled and the credit can only be claimed for 4 years per student. In many cases, dual credit students are not paying the full rate of a regular students. In my opinion (and that is all it is as we cannot give tax advice), taxpayers claiming a small educational tax credit for dual credit costs may be shorting themselves on the amount of total credits they could claim over the complete tenure of a student obtaining a Bachelor's degree. I realize academics are changing and some dual credit students are now completeing their first two years of their UG degree so if regular enrollment at the university is not expected to last 4 full years, it certainly makes sense to claim the AOTC for all four years, regardless of the type of enrollment.
I hope that makes sense and this is purely for your benefit in understanding why and how we report so that when the taxpayer or tax preparer tells us our forms are wrong, we have some background on why it is not.
Incidentally, I just recently had another CPA tell me I was wrong for including exemptions in Box 5 because Turbo Tax was telling him that was income. However, once we walked through it and I pointed out that the net of Box 1 and Box 5 should be the focus. That net amount should determine whether he was eligible for a credit (Box 1 > Box 5 which in this case it was and was the exact credit he was looking for) or subject to potential taxable income (Box 5 > Box 1). He realized he could be misinterpreting the software's classification and he was getting the appropriate deduction. Keep in mind, that it is always possible that software have bugs that need to be resolved or user error is always at play so all we can do is stand by our process and the IRS regulations and refer the person back to their tax expert for a solution or other explanation.
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Christine Blakney
Senior Managing Director of Student Business Services
Texas Tech University
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Original Message:
Sent: 02-05-2026 09:30 AM
From: Dave Tassione
Subject: Dual Credit/1098T/W-9S Letter
What do schools do when it comes to incomplete or missing SSNs for dual credit students? Tuition is being paid, so 1098T forms are calculated and generated, but according to guidelines, schools need to make an attempt to obtain accurate/corrected SSN/ITIN information.
Is there any reason W-9s letters would not be sent to dual credit students if they will be receiving a 1098T form? If no attempt is made, the IRS will penalize a school for non-compliance based on guidelines. Or am I missing something about dual credit students?
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Dave Tassione
Manager – Student Accounting and ERP Coordinator
Harper College
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