IRS Audit Reconsideration

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When Can You Request an Audit Reconsideration?

Several specific circumstances make you eligible to request an audit reconsideration from the IRS. The qualifying situations include:

• New information that wasn’t available during your original audit – missing receipts, bank statements, or supporting documentation you’ve since located.
• Computational errors made by the IRS during your audit – mistakes in tax calculations, penalties, or interest assessments.
• Never received the original audit notices – mail delivery issues or address changes prevented you from responding.
• Discovery of additional business expense documentation – misfiled receipts, closed account statements, or overlooked deductions.
• Substitute for return (SFR) assessments – when the IRS estimated your liability, and you now have the actual records to file an accurate return.

Understanding these qualifying circumstances helps you evaluate whether your situation warrants pursuing audit reconsideration. Each scenario requires specific supporting evidence to build a compelling case for the IRS to reopen your audit.

How to Request an IRS Audit Reconsideration

Requesting an audit reconsideration requires following specific procedures to ensure your request receives proper attention. The process involves several key steps:

1. Submit a written request to the IRS examining office that conducted your original audit, clearly stating that you’re requesting an “audit reconsideration.”
2. Include required identifying information – your name, current address, Social Security number or EIN, and the tax years in question.
3. Provide a detailed explanation of why reconsideration is warranted, specifying the new information or errors you’ve identified.
4. Include all new supporting documentation that wasn’t previously submitted, organized for clarity.
5. Send your request via certified mail with return receipt requested to ensure proof of delivery.

Following these procedural requirements increases your chances of success and ensures the IRS processes your request properly. Keep copies of everything you submit, including your certified mail receipts.

Required Documentation and Evidence

Success in audit reconsideration heavily depends on the quality and relevance of your documentation. The IRS won’t reconsider a case simply because you disagree with its findings—you need concrete evidence that supports your position or demonstrates its error.

For business-related disputes, comprehensive financial records are necessary, and may include:

• Bank statements showing business transactions
• Canceled checks that prove expense payments
• Invoices and receipts for claimed deductions
• Contracts that establish business relationships
• Accounting records that support your reported income and expenses

For individual taxpayers, the required evidence varies:

• Itemized deductions – receipts and statements proving expenses
• Medical deductions – healthcare bills and payment records
• Charitable contributions – receipts from qualified organizations
• Income assessments – complete records showing all income sources and corrections

Professional assistance from a tax lawyer, CPAs, or enrolled agents can be invaluable—they know what the IRS finds most compelling and can communicate effectively on your behalf.

Timeline and Response Expectations

The audit reconsideration process typically extends over several months, with timeframes varying based on complexity and IRS workload. Understanding these timelines helps you manage expectations:

• Acknowledgment within four to six weeks – you’ll receive a reference number for future correspondence.
• Case assignment – an examining officer reviews your documentation and may request additional information.
• Determination issued – the IRS will uphold the original audit, modify the assessment, or completely reverse the previous findings.
• Adjustments and refunds – if you prevail, the IRS will adjust your account and issue refunds for overpaid taxes, penalties, or interest (subject to the refund statute of limitation).

Common Reasons for Audit Reconsideration Requests

Understanding why other taxpayers request audit reconsideration can help you decide if it’s right for you:

• Missing documentation – misplaced receipts due to moves, disasters, or overlooked records.
• Computational errors – mistakes in tax code application or liability calculations.
• Changes in personal circumstances – divorce, business dissolution, or new financial records.
• Life circumstances beyond your control – serious illness, emergencies, or military deployment that prevented timely response.
• Substitute for return cases – correcting overestimated liabilities when actual returns are prepared.

Consider professional representation by a tax attorney – who can navigate IRS procedures and present evidence more effectively. Careful preparation, compelling evidence, and expert guidance can significantly improve your chances of a successful IRS audit reconsideration.

Facing a Tax Problem? We’re Here to Help.

At Hughes Noff Tax Law, we know how overwhelming it can feel when the IRS or state tax authorities get involved. Whether you’re dealing with an IRS audit or tax dispute, international tax compliance, or tax debt resolution, we’re here to provide you relief and reduce your anxiety. Let us deal with the federal government—so you don’t have to.

We approach every client with empathy and provide the advocacy, direction, service, and resolution they deserve. We have over 25 years of combined experience resolving complex tax controversy and understand the unique and sensitive nature of these matters. As both attorneys and CPAs, we understand the law and the numbers. Our clients appreciate the clarity and peace of mind we help restore—read their stories here.

Contact us today or call 410-694-7758 to schedule your consultation.