If the IRS completed an audit and assessed additional tax that you believe is incorrect, audit reconsideration may allow you to ask the IRS to review the assessment again.
Audit reconsideration is commonly considered when a taxpayer did not participate fully in the original audit, did not submit important records, or later obtains documentation that could change the result.
Attorney Todd S. Unger helps taxpayers evaluate disputed IRS audit assessments and determine whether audit reconsideration or another procedural option is appropriate.
When Can Audit Reconsideration Be Available?
Audit reconsideration is an IRS administrative process for certain examination assessments that may need reevaluation. It is not an automatic second appeal, and submitting a request does not guarantee that the IRS will reopen or change the assessment.
It may be worth evaluating whether relevant information was not considered during the original examination, whether the taxpayer did not fully participate, whether records were unavailable, whether a credit was disallowed, or whether the assessment appears to have been based on incomplete or incorrect information.
What Documents Should You Gather?
A reconsideration request should focus on the specific adjustments being disputed. Start with the original examination report and IRS notices, then gather records that directly support the items you believe were incorrectly assessed.
The relevant evidence depends on what the IRS changed. New information generally means information the IRS did not consider during the original examination, not necessarily a document created later.
What Happens After You Request Reconsideration?
The IRS reviews the request, the disputed adjustments, and the new supporting information. Depending on the case, the IRS may request additional documents, accept some or all of the taxpayer’s position, make no change, or determine that another procedure is more appropriate.
Requesting reconsideration does not automatically stop IRS collection. If a levy, lien, wage garnishment, or Collection Due Process deadline is also involved, address that issue separately and promptly.
When Should You Talk With a Tax Attorney?
Legal review can be especially useful when the assessment is substantial, the audit involved business income or deductions, multiple tax years are affected, records need to be reconstructed, collection has already started, or it is unclear whether reconsideration is the correct procedure.
Todd S. Unger can review the examination history, identify disputed adjustments, evaluate the available evidence, and determine whether to pursue audit reconsideration, an administrative appeal, a refund procedure, or another remedy.
Was Your IRS Audit Assessment Based on Missing or Incomplete Information?
Gather the audit report, IRS notices, disputed adjustments, and supporting records. Todd S. Unger can review the case and help determine whether audit reconsideration is an appropriate next step.