Closed audit · Unpaid assessment · New information
Washington, DC IRS audit reconsideration.
Mr. Powell builds and files audit reconsideration requests for individuals and closely held businesses, and he takes those matters nationwide from 1629 K Street NW, Suite 300 in Washington, DC. Audit reconsideration is an IRS administrative process for reevaluating certain audit assessments. Eligibility and the supporting record come first. It is not a substitute for every appeal, Tax Court deadline, refund claim, or collection remedy.
Procedures and eligibility depend on the examination division, the notice issued, and the facts of the matter.
The reconsideration procedures described on this page were checked on irs.gov on September 4, 2026. The notice in hand controls over this summary.
Who qualifies for IRS audit reconsideration?
IRS guidance states that audit reconsideration generally concerns an audit assessment that remains unpaid, disputed adjustments, and new information that was not considered during the original examination. The process may also apply to an IRS computational or processing error. If the assessed tax has been paid in full, the proper path may instead be a refund claim.
A taxpayer should identify the adjustments in dispute and connect each one to the new records or explanation offered for reconsideration. Repeating an argument without new supporting information does not meet the purpose of the process.
Some assessments cannot be reconsidered at all. The Internal Revenue Manual states that reconsideration criteria are not met when the assessment came from a closing agreement under 26 U.S.C. section 7121, from a compromise under section 7122, or from final TEFRA proceedings, and that the IRS will not reopen a matter the Tax Court decided or a case settled by mutual concession on Form 870-AD. A request in one of those postures draws a Letter 916-C. Check the closing document before building the request. Internal Revenue Manual 4.13.1 was checked on irs.gov on September 10, 2026.
Official source: Internal Revenue Manual 4.13.1
Official source: IRS correspondence audit reconsideration
Official source: IRS Publication 3598
The request
Build the request around the disputed adjustments.
Obtain the audit report and identify each adjustment being disputed.
Confirm the payment and procedural posture before choosing reconsideration.
Separate information the IRS previously considered from information it did not.
Connect each new document to a specific adjustment and factual proposition.
Prepare the written request, supporting index, and copies for submission to the appropriate IRS office.
Deadlines outside reconsideration still matter.
An audit reconsideration request does not erase a deadline stated in an IRS notice. A Notice of Deficiency, collection notice, appeal letter, or refund period may present a different procedural path with its own deadline. Read the current notice before relying on reconsideration.
IRS Publication 3598 says the IRS may delay collection activity after it receives the information needed for an eligible reconsideration request and may resume collection if requested documentation is not provided. Do not assume that sending a request alone stops collection. Read each collection notice and confirm the account's current status.
Review IRS Letter 525, IRS Letter 3219, or use the IRS Letter Check for a supported notice code.
Questions
Common questions.
What does an IRS audit reconsideration attorney in Washington, DC do?
An IRS audit reconsideration attorney represents individuals and closely held businesses asking the IRS to reevaluate certain unpaid audit assessments when new information was not considered during the original examination. Law Office of Alexander Powell, PLLC has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents those clients in IRS examinations nationwide. Eligibility and the supporting record come first. It is not a substitute for every appeal, Tax Court deadline, refund claim, or collection remedy.
What is IRS audit reconsideration?
Audit reconsideration is an IRS administrative process for reevaluating an audit assessment when the taxpayer supplies information the original examination did not consider. IRS Publication 3598 describes it. It generally concerns an assessment that remains unpaid, and it may also reach an IRS computational or processing error. Eligibility and the supporting record come first. It is not a substitute for an appeal, a Tax Court petition period, a refund claim, or a collection remedy.
When is audit reconsideration available?
IRS guidance states that audit reconsideration generally concerns an audit assessment that remains unpaid, disputed adjustments, and new information that was not considered during the original examination. The process may also apply to an IRS computational or processing error. If the assessed tax has been paid in full, the proper path may instead be a refund claim.
Does an audit reconsideration request stop IRS collection?
An audit reconsideration request does not erase a deadline stated in an IRS notice. IRS Publication 3598 says the IRS may delay collection activity after it receives the information needed for an eligible reconsideration request and may resume collection if requested documentation is not provided. Do not assume that sending a request alone stops collection. Read each collection notice and confirm the account's current status.
What happens after the IRS reviews a reconsideration request?
The IRS may allow the request in full, allow it in part, or disallow it. When preliminary findings would disallow all or part of a reconsideration request, the Internal Revenue Manual generally provides for a letter offering an opportunity to request review by a manager or the IRS Independent Office of Appeals. The actual next step depends on the letter issued in the matter.
Is audit reconsideration the same as IRS Appeals or Tax Court?
No. Audit reconsideration is an administrative request to the IRS about an assessment it already made. The IRS Independent Office of Appeals is a separate function that reviews disputed adjustments and collection actions. The United States Tax Court is a court, and after a Notice of Deficiency the period to petition it runs under Internal Revenue Code section 6213(a). A collection notice, an appeal letter, or a refund period may each present a different procedural path with its own deadline, and the current notice says which one applies.
Possible results.
The IRS may allow the request in full, allow it in part, or disallow it. When preliminary findings would disallow all or part of a reconsideration request, the Internal Revenue Manual generally provides for a letter offering an opportunity to request review by a manager or the IRS Independent Office of Appeals. The actual next step depends on the letter issued in the matter.
Official source: Internal Revenue Manual 4.10.11
Return to the IRS audit defense page. If collection notices have already arrived, start with How do I respond to an IRS collection notice?
Related pages
Related audit reconsideration resources.
- IRS audit defenseReturn to the examination hub when the dispute still concerns an open or recently closed audit.
- IRS AppealsIndependent Office of Appeals review is a separate path from reconsideration.
- U.S. Tax CourtA Notice of Deficiency states a Tax Court deadline. That path is separate from reconsideration.
- How do I respond to an IRS collection notice?Read the paper notice first if collection has already begun on an unpaid assessment.
- IRS collectionsUnpaid balances, liens, levies, and payment options.
- Information Document RequestForm 4564 IDRs are how the examination record was built before the assessment.
- IRS Letter CheckLook up the code printed on a supported IRS letter.
Send the letter code and the date printed on it.
Tell me what the audit report changed, whether the assessment remains unpaid, and what new information was not considered. Send only a high-level summary.
Schedule an initial consultationRequesting a consultation does not make Mr. Powell your lawyer, provide legal advice, or protect a deadline.
Law Office of Alexander Powell, PLLC. 1629 K Street NW, Suite 300, Washington, DC 20006.