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IRS Examination and Appeals

Audit Reconsideration

Audit reconsideration is the route back into an examination that has already closed against you. It is for people who never received the notices, never had the chance to respond, or have information the IRS never saw.

Also called: audit reconsideration, reopening a closed audit, audit I never knew about.

When it applies

The typical case is a taxpayer who moved, never received the correspondence, and discovered the problem when a refund was taken or a levy arrived. It also covers audits where documents were submitted and not considered, and assessments the IRS made from a substitute return it prepared itself.

The request needs to bring something new. Disagreeing with a conclusion the IRS already reached on evidence it already saw is not usually enough. Documentation that was never in front of the examiner is what moves it.

What it can achieve

A successful reconsideration reduces or removes the assessment, and the penalties and interest calculated on it fall away with it. Collection can often be held while the request is under review, though that is not automatic and is worth requesting explicitly.

There are limits. Reconsideration generally is not available where the balance has already been paid, where a court has ruled on the matter, or where you signed an agreement closing the issue. Which of those applies to you is worth establishing before the work begins.

This is likely relevant to you if

  • An audit closed against you without your knowledge
  • You have records the examiner never received
  • The assessment came from a return the IRS filed on your behalf
  • You disagree with an assessment and have new information to support it

Professionals who handle Audit Reconsideration

Certified Taxpayer Representative holders are listed first, then by membership level. Every listing is a licensed professional reviewed by hand before it appears.

CTRCertified Taxpayer Representative, Verified
Portrait of Dan Henn, CPA, CTR™

Dan Henn, CPA, CTR™

Daniel Henn, CPA, PA

  • CPA
No reviews yet
Rockledge, FL
  • IRS Power of Attorney Representation (Form 2848)
  • Installment Agreement Negotiation
  • Currently Not Collectible Status
  • +27 more
Aims to reply within 24 to 48 hours
Accepting clients
National

Common questions

How long do I have to request reconsideration?

There is no single fixed deadline in the way there is for an appeal, which is one reason it remains available when other routes have closed. Acting sooner is still better, because collection continues in the meantime.

Will collection stop while it is considered?

It can be suspended, but it is not automatic. A representative will normally ask for a hold at the same time the request is filed.

What if reconsideration is denied?

Appeal rights may be available, and other routes such as an Offer in Compromise based on doubt as to liability may fit the facts.

This page is general information about how the IRS handles this kind of matter. It is not advice about your situation, and no outcome is being promised. Results depend on your own facts. Speak to a licensed professional before you act. The directory is a free member benefit of Tax Resolution Academy®, and there is no way to pay for a higher position in it.