An IRS audit does not always produce a final, unalterable result. If the IRS assessed additional tax after an examination you did not fully participate in — or if you have documentation that was never considered — audit reconsideration is a formal administrative procedure that allows you to request a new review of the assessment.

Audit reconsideration is not an appeal. It is a separate IRS process governed by the Internal Revenue Manual (IRM 4.13.1) that allows a taxpayer to submit information the IRS did not have when it made the original determination.

Audit reconsideration is an IRS administrative procedure that allows a taxpayer to request that the IRS reexamine a previously closed examination when:

• The taxpayer did not appear for the audit or respond to IRS correspondence;
• The taxpayer disagrees with the IRS's determination and has documentation that was not previously considered;
• The IRS made a computational or processing error; or
• The taxpayer did not file a return and the IRS prepared a substitute for return (SFR) under IRC §6020(b).

The procedure is described in IRM 4.13.1 and IRS Publication 3598. It is available for income tax, self-employment tax, and certain other tax types.

Audit reconsideration does not suspend collection. The IRS may continue collection activity while reconsideration is pending unless the taxpayer separately requests a collection hold or enters into a collection alternative.

A taxpayer may request audit reconsideration when all of the following apply:

1. The IRS has made an assessment based on an audit;
2. The taxpayer disagrees with all or part of the assessment;
3. The taxpayer has not already paid the full amount assessed; and
4. The taxpayer has not previously agreed to the assessment by signing Form 870 (Waiver of Restrictions on Assessment) or a closing agreement — unless the taxpayer has new information that was not available at the time of the agreement.

A taxpayer who signed Form 870 or a closing agreement generally cannot use audit reconsideration to challenge the agreed items. However, if the taxpayer has documentation that was not available and could not have been obtained at the time of the original examination, the IRS may consider the request.

The strength of an audit reconsideration request depends entirely on the documentation submitted. The IRS will not reconsider an assessment based on a taxpayer's assertion alone.

Useful documentation includes:

• Receipts, invoices, and bank statements supporting deductions the IRS disallowed;
• Contracts and closing documents for transactions the IRS questioned;
• Payroll records and employment agreements for compensation-related issues;
• Basis records for assets sold — purchase documents, improvement records, depreciation schedules;
• Amended returns if the original return contained errors;
• Third-party records — letters from employers, financial institutions, or other parties confirming the taxpayer's position;
• Prior-year returns establishing carryforward items; and
• Medical or hardship records if the taxpayer was unable to participate in the original examination.

The documentation should be organized, clearly labeled, and directly tied to the specific items the IRS adjusted.

There is no official IRS form for audit reconsideration. The request is submitted as a written letter to the IRS campus that processed the original examination.

The letter should include:

1. The taxpayer's name, address, Social Security number or EIN, and tax year at issue;
2. A clear statement that the taxpayer is requesting audit reconsideration under IRM 4.13.1;
3. A copy of the IRS examination report (Form 4549 or CP2000 notice) showing the adjustments;
4. A specific explanation of each item being disputed;
5. The supporting documentation for each disputed item; and
6. A statement of the amount the taxpayer believes is correct.

The request should be sent by certified mail with return receipt to create a documented record of submission.

After receiving the request, the IRS will:

1. Acknowledge receipt — typically within 30 days;
2. Review the documentation — an examiner or tax examiner will review the submitted materials against the original examination file;
3. Issue a determination — the IRS will either accept the taxpayer's position (in full or in part), request additional information, or deny the request with an explanation.

If the IRS accepts the reconsideration, it will abate all or part of the assessment and issue a revised notice. If the IRS denies the request, the taxpayer retains the right to request Appeals consideration or, if the assessment is still within the Tax Court petition period, to file a Tax Court petition.

The IRS does not have a statutory deadline for completing audit reconsideration. Processing times vary by campus and complexity but typically range from 60 to 180 days.

When a taxpayer fails to file a required return, the IRS may prepare a Substitute for Return (SFR) under IRC §6020(b) using information from third-party sources — W-2s, 1099s, and other information returns.

SFR assessments are frequently overstated because the IRS uses gross income figures without the deductions, credits, filing status, and exemptions the taxpayer would have claimed. A taxpayer who files an original return after an SFR assessment — or who submits an amended return with proper deductions — can often substantially reduce the liability through audit reconsideration.

The IRS treats a properly filed original return as a reconsideration request in SFR situations.

Act quickly. Although audit reconsideration does not have a statutory deadline, collection activity continues while the request is pending. The sooner the request is submitted, the sooner collection pressure may be reduced.

Request a collection hold. When submitting an audit reconsideration request, consider simultaneously requesting that the IRS place a hold on collection activity. The IRS has discretion to suspend collection while reconsideration is pending, but it is not automatic.

Keep copies of everything. Maintain copies of all documents submitted and all IRS correspondence received. If the reconsideration is denied, the documentation record will be important for any subsequent appeal or Tax Court proceeding.

Consider professional representation. Audit reconsideration involves navigating IRS procedures, organizing documentation, and making legal arguments about the proper tax treatment of specific items. A qualified representative — an Enrolled Agent, CPA, or tax attorney — can substantially improve the outcome.

Audit reconsideration is a valuable but underused remedy for taxpayers who face IRS assessments based on incomplete information. It is not a second chance to make arguments that were already considered and rejected — it is a mechanism for presenting documentation that was not part of the original examination record.

If you received an IRS assessment after an audit you did not fully participate in, or if you have records that were never submitted to the IRS, contact us to discuss whether audit reconsideration is the right path forward.

Governing authority: IRM 4.13.1; IRS Publication 3598; IRC §6020(b); IRC §6213.

Related: IRS Representation: What It Is and When You Need It · The IRS Second Examination Rule · IRS Audit Triggers