IRS Reconsideration Audit Services
If you were hit with an IRS audit result that feels wrong, you may still have a path to challenge it. Audit reconsideration can allow taxpayers to present additional information and request that the IRS review an assessment that should be corrected.
Whether you missed an appeal deadline, never had a fair chance to present records, or believe the IRS assessed too much tax, Todd Unger can evaluate your situation and help you determine the best next step.
Are you facing unsettling results from an IRS audit? Did you inadvertently miss the deadline for an IRS Appeal or the opportunity to contest in Tax Court? Are you being burdened with a tax demand you genuinely believe is incorrect? You might be in a situation where you don’t owe the stated amount, and with our expertise, we’re here to help ensure you’re treated fairly.
Understanding Tax Law
It’s crucial to understand that Internal Revenue Code § 6404(a) empowers the IRS to rectify any tax assessment, along with its associated interest and penalties, if found excessive, made in error, implemented illegally, or raised after the statute of limitations has lapsed. Should you be faced with an erroneous tax assessment that hasn’t been settled, there are provisions wherein the IRS might consider a request for an audit reconsideration.
Diving deeper, the Internal Revenue Manual 4.13.1.4 sets out the procedures the IRS adopts during an audit reconsideration request evaluation. For a reconsideration request to be accepted by the IRS, the following conditions must be met:
- The taxpayer has to have duly filed a tax return.
- The tax assessment should either remain unsettled or the Service has disapproved tax credits, which the taxpayer contests.
- The taxpayer must specify the adjustments being contested.
- The taxpayer must present additional information that wasn’t considered in the initial examination.
When Audit Reconsideration May Be Possible
Audit reconsideration is not right for every case, but it can be an important option when the IRS reaches a result without considering all of the relevant facts. In many situations, taxpayers miss the chance to participate in an audit because notices are missed fully, deadlines pass, records are incomplete, or the IRS relies on limited information.
In practical terms, reconsideration may be worth exploring if you did not fully participate in the original examination, if the IRS used incomplete or incorrect information, if you now have records that were not previously reviewed, or if the assessed balance remains unpaid. You need a path to challenge it. These cases are highly fact-specific, which is why careful review matters before taking action.
Our Audit Reconsideration Process
These cases often turn on details, documentation, and timing. A strong reconsideration request usually requires much more than simply telling the IRS the audit was wrong.
We examine what happened during the original audit, the adjustments made, and the opportunities missed.
We identify what the IRS relied on and what additional information can now be presented.
We pinpoint the specific items that should be challenged and explain why the original result was flawed.
We assemble the legal and factual support needed to request that the IRS reevaluate the assessment.
If the IRS requests clarification or additional records, we will continue advocating on your behalf.
How We Can Help You
Our dedicated team will access the auditor’s records under the Freedom of Information Act, allowing us to review in detail the decision-making process regarding your IRS tax debt. Armed with this insight, we’ll delve into the legal and tax implications of your audit. This will help us determine whether an appeal is in your best interest.
Should an appeal be the recommended path, we’re equipped to craft an audit reconsideration request advocating for correcting any excessive tax claims. This request will detail why you were unjustly denied the chance to provide pertinent data and contest the initial audit outcome. We’ll also highlight how presenting this data during the original audit could have favorably impacted your tax obligations.
The maze of legal and tax intricacies intertwined in an audit necessitates the expertise of a seasoned IRS tax attorney. A dedicated IRS tax lawyer stands as your best chance to appeal an IRS verdict and potentially overturn an unfavorable IRS tax assessment.
Why Legal Representation Matters
An audit reconsideration request is not just about sending more paperwork to the IRS. It requires a clear explanation of what went wrong, why the original assessment should not stand, and how the new information changes the result. The right legal strategy can make a major difference in how your request is framed and how your evidence is presented.
With experienced tax counsel, you can better evaluate whether reconsideration is the right path, avoid common procedural mistakes, and strengthen your position if the IRS pushes back. Every case depends on its facts, prior IRS history, and the quality of the information being submitted.
Do Not Assume the Audit Result Is Final
If the IRS assessed too much tax and you now have the information needed to challenge it, this may be the right time to act.
Reach Out For Expert Guidance
With an extensive track record of managing tax controversies, New Jersey tax attorney Todd S. Unger is well-equipped to handle cases like yours, benefiting individuals and businesses throughout the state. Entrust us with gathering vital financial data, navigating IRS documentation intricacies, and negotiating a resolution tailored to your needs. Contact us now for the expert representation you deserve. (877) 544-4743
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Frequently Asked Questions
Here are answers to some of the most common questions about IRS audit reconsideration.
What is IRS audit reconsideration?
IRS audit reconsideration is a process that may allow a taxpayer to ask the IRS to review an audit result again when new information becomes available or when the original assessment was made in error.
Can I request reconsideration if I missed the audit?
In many cases, yes. Taxpayers who missed the original audit or did not provide all relevant information may still be able to request reconsideration if the balance remains unresolved and the IRS requirements are met.
Do I need new information for audit reconsideration?
Generally, yes. The IRS usually expects additional information that was not considered during the original examination.
Is audit reconsideration the same as an appeal?
No. Audit reconsideration is different from a formal IRS appeal. It may still be an option when appeal deadlines were missed or when new evidence needs to be reviewed.
Should I hire a tax attorney to reconsider an audit?
These cases often involve procedural issues, legal arguments, and detailed financial records. Experienced tax counsel can help present the strongest possible request and reduce the risk of avoidable mistakes.