@tbrown21
There are only a limited number of reasons why a school would not be required under the regulations to issue a 1098, and this taxpayer’s situation does not meet any of those exceptions.
Also, look at section (g)(8), “payee statement required.“ The 1098-T is the payee statement. Even though a federal EIN is only required for the American opportunity credit, a 1098 is required for both the American opportunity and lifetime learning credit.
And in any case, I believe that if the taxpayer goes so far as to check the box for “the school is not required to issue a 1098“ and enters the tuition paid without an EIN, TurboTax will still not accept the entry. This is likely a requirement imposed by the IRS e-filing system, that requires all tax providers to follow certain compliance guidelines in order to connect to the system. I suggested that the taxpayer can use an override and file by mail, but I think their credit will ultimately be denied for the reasons I indicated.
