Closed audit · Unpaid assessment · New information
Asking the IRS to reconsider an audit assessment.
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.
Start with eligibility.
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.
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.
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.
A simple first step
Start with what you know.
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. Documents can be reviewed later, if needed.
Start here