IRS Audit Reconsideration Reference Guide
Understanding Audit Reconsideration
An audit reconsideration request asks the IRS to reopen and reexamine a closed audit when you have information the agency did not consider during the original examination or when the
IRS made a mathematical or processing error. This process occurs after an audit has ended and you have received a written examination report, also known as a Revenue Agent Report.
The IRS Examination function determines whether to reconsider based on specific criteria, including substantiating evidence that the agency did not review, proof that documentation existed but was unavailable during the audit, or clear errors in IRS computational processes.
Reconsideration is not an appeal and does not replace your right to pursue formal Appeals or
Tax Court if those options remain available.
Who Should Use This Guide
You should use this guide if your audit was formally closed, you received a written examination report, you have documents or evidence that the IRS did not see during the original audit, or you were unable to produce the required records during the examination. Still, you can now locate them, or you believe the IRS made a mathematical or procedural error in its calculations.
This guide also applies if you want to request the IRS reopen the case before pursuing other remedies or if the audit outcome created a tax debt you are now disputing.
Do not use this guide if your audit is still ongoing and you remain in communication with the examination agent, you received only a routine notice or informational letter rather than a closed examination report, or you want to file a formal appeal of the audit result through the IRS
Appeals Office. This guide does not apply if the assessment statute of limitations has expired and the IRS can no longer increase your assessment, you want to dispute IRS collection actions such as levies or wage garnishments, or you received a Statutory Notice of Deficiency and your ninety-day window to petition the Tax Court is still open.
What Determines Success
The single biggest factor in audit reconsideration success is whether you have substantiating evidence the IRS did not review during the original examination, or whether you can identify a clear IRS error in computation or processing. The IRS focuses first on whether the new information directly addresses an item the agent examined and disallowed, whether the
information changes the facts rather than your interpretation of those facts, and whether the request meets reconsideration criteria while the assessment statute remains open.
Contemporaneous records, such as bank statements, invoices, and canceled checks, dated during the year in question, carry the most weight. Documentary proof that the evidence existed and was in your control, such as correspondence showing that you requested records from third parties after the audit closed, significantly strengthens your case. Clearing IRS arithmetic errors visible in the examination report, or identifying specific line items where the agent made factual mistakes, also provides strong grounds for reconsideration.
Filing a reconsideration request without supporting documents typically signals that you lack evidence and results in a quick denial. Resubmitting documents the agent already reviewed wastes time and demonstrates you either misunderstand the reconsideration process or lack better evidence. Waiting years after the examination report closes before requesting reconsideration reduces your chances of success, as files become harder to locate and agents move to other positions.
Essential Steps for Audit Reconsideration
1. Locate and review your original examination report carefully, noting which line items, deductions, or income amounts the agent disallowed or adjusted and the specific reason given for each change.
2. Verify that the assessment statute of limitations has not expired by checking the statute expiration date on your IRS Account Transcript or examination report.
3. Gather all documents the IRS did not consider during the original examination that directly address the disallowed items, including bank statements, invoices, receipts, contracts, and canceled checks dated during the tax year being audited.
4. Create a written summary explaining why each piece of information was not available during the original audit, such as the document being held by a third party, records being discovered after the audit closed, or your initial unawareness of the document’s relevance.
5. If the issue involves an IRS error, identify the specific error with a reference to the examination report page and line number, such as an incorrect calculation or misapplied fact.
6. Assemble one organized file with clearly labeled sections: the examination report, the new information organized by audit issue, your written explanation, and any prior
correspondence about the evidence.
7. Submit your reconsideration request in writing to the IRS campus or office that issued the examination report, following any specific submission instructions provided in that report.
8. Send the request by certified mail with a return receipt requested to create proof of delivery and date.
9. In your cover letter, state the specific reason for reconsideration: information the IRS did not consider, previously unavailable documentation, or an IRS mathematical or processing error.
10. Do not resubmit documents that the agent already examined or make arguments about tax law interpretation without supporting evidence that changes the underlying facts.
11. Monitor correspondence and follow up if you receive no response within 90 to 120 days, recognizing that processing times vary significantly based on case complexity and the
IRS workload.
12. If the IRS denies reconsideration or partially grants it, request a written explanation of the basis for the decision to understand what the Examination function found persuasive or unpersuasive.
Common Errors to Avoid
- Submitting a reconsideration without new information or a clear identification of IRS
errors will likely result in the agency denying your request quickly. Resubmitting documents that the agent has already reviewed demonstrates a lack of genuinely new evidence and undermines the credibility of the submission.
- Arguing about tax law or claiming the IRS misinterpreted the Internal Revenue Code
without presenting new factual information will cause your request to be viewed as an improper appeal rather than a legitimate reconsideration.
- Submitting undated, reconstructed, or self-created documents as new evidence fails to
meet IRS standards, as the agency requires source documents or copies from third parties, such as banks.
- Filing a reconsideration request by phone without a written follow-up or sending your
request to the wrong IRS office may result in your submission being lost or rejected.
- Failing to organize documents clearly or provide a written explanation of why each piece
of information is new and relevant makes it difficult for the IRS to evaluate your request and increases the likelihood of denial.
When to Seek Professional Assistance
You should seek professional help if you cannot locate or reconstruct the necessary information yourself, or if you are unsure whether your evidence meets Audit Reconsideration IRS standards set by the Internal Revenue Service.
Professional representation becomes critical when the audit examination report references multiple years, complex issues such as depreciation or business structure, a prior substitute for return, or significant dollar amounts that affect your overall tax liability or tax balance.
You need guidance from a tax professional if you received a Statutory Notice of Deficiency following an audit notice or tax audit and must decide whether to request reconsideration or petition the Tax Court, as the choice directly affects your rights and the underlying tax assessment.
Professionals can also assist if the IRS requests additional information during reconsideration, denies your request, or when unresolved issues begin to impact a payment plan, Installment
Agreement, or trigger collection hearings tied to an unpaid tax return.
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