Quick Answer: Audit reconsideration lets you ask the IRS to revisit an assessed, unpaid audit liability or a reversed tax credit using relevant information it did not consider, or to correct an IRS computational or processing error. Eligibility, submission routing, collection activity and filing deadlines require separate attention.
A missed notice or an incomplete audit file can leave an assessment that does not reflect the available records. Start with the audit report and current account status. A request to reconsider an assessment is different from responding to a proposed adjustment before assessment.
Check whether reconsideration fits the assessment
Under the IRS reconsideration criteria, the taxpayer must have filed a return, identify the disputed adjustments and provide information not previously considered, unless the issue is an IRS computational or processing error. The assessed tax generally must remain unpaid, or the dispute must involve reversed credits. If the IRS prepared a substitute for return, filing a complete, signed original delinquent return is part of the appropriate reconsideration procedure. A currently open examination with no assessment should be addressed with the office handling that examination.
New evidence means information the IRS did not previously consider. Documents sent earlier but lost or overlooked can still be relevant; explain that history. Records must support the audited year and adjustment. A different explanation without supporting facts does not ensure a changed result.
Recognize exclusions and other routes
The Taxpayer Advocate Service explains the main exclusions: certain signed agreements, including Form 906 closing agreements, accepted offers in compromise and Form 870-AD agreements with Appeals, and final court determinations can prevent reconsideration. Finally determined partnership adjustments also require separate analysis under the applicable partnership procedures.
If the assessment is fully paid and no reversed refundable credit remains in dispute, evaluate a timely formal refund claim. Form 1040-X generally serves that purpose for individual income tax; other taxes and return types can require different forms. Do not assume sending a reconsideration letter satisfies the requirements for a refund claim.
| Current situation | Issue to address |
|---|---|
| Proposed audit changes; response rights still open | Respond to the examination and preserve available administrative appeal and court rights. |
| Unpaid assessed audit tax or a reversed credit | Check reconsideration eligibility and supporting evidence. |
| Fully paid assessment | Review the proper refund claim and its limitations period. |
| Active collection notice | Address collection rights and any hold request separately from the merits of the assessment. |
Related reading: “Are Services Taxable in Florida? Common Sales Tax Misunderstandings” covers Florida Service Sales Tax in more detail.
Protect deadlines and address collection separately
A reconsideration request does not itself extend a Tax Court petition deadline, an administrative appeal deadline or the time to claim a refund. Read every notice and calendar its specific response date. The IRS expressly explains that reconsidering a proposed deficiency does not extend the period for petitioning Tax Court. See IRS audit procedures.
Refund claims generally must be filed within three years after filing the return or two years after paying the tax, whichever is later. Separate limits on the refundable amount and exceptions can apply. Check the applicable rules before relying on that general period; Publication 556 discusses refund claims and appeal rights.
Collection does not automatically stop merely because you call or submit a request. Ask the responsible IRS office whether a temporary hold is appropriate and confirm its status and duration. Continue required installment-agreement payments while the request is pending. A collection hold is not a decision reducing the assessment, and unresolved amounts may continue to accrue applicable interest and penalties. Publication 3598 explains payment and collection considerations.
Prepare one organized submission
- Identify the case. Gather the notices, return, account information, prior correspondence and examination report, including Form 4549 if available.
- Explain each disputed item. State the adjustment, the correction requested and the reason. Cross-reference supporting exhibits. Form 12661 can help organize disputed issues, but a clear written request can be used.
- Attach relevant copies. Match receipts, contracts, basis records or other documents to the year and issue. Keep originals and a complete copy of the package.
- Verify the destination. Use the audit report and current official instructions to identify the responsible office. Different examination and substitute-for-return cases have different routing. If the address is unclear or correspondence conflicts, confirm with the IRS using an official contact channel before sending records.
- Track delivery and follow-up. Retain proof of submission and record calls, requests for additional information and response dates.
Publication 3598 describes these submission steps. Its approximately 30-day initial-response guidance is not a guaranteed response or completion date. If you have no acknowledgment around that point, contact the IRS to confirm receipt and routing; respond promptly to any document request without assuming other deadlines have stopped.
Review the result and representation scope
The IRS may remove the assessment, reduce it in part or leave it unchanged. Review the written explanation against the evidence. The Taxpayer Advocate Service describes requesting an Appeals conference if you disagree; a qualifying refund claim may be another route. Eligibility and deadlines still matter.
An accountant can help organize records, but that title alone does not grant full representation rights. Publication 947 explains who may practice before the IRS. An eligible representative generally uses Form 2848 for the specified matters and periods. IRS practice authority does not automatically authorize representation in court.
For a review of your notices and records, contact CPA Firm South Florida through its IRS representation page. Confirm the engagement’s scope, responsible representative, fees and deadlines before relying on the firm to act.
Frequently asked questions
Can I resubmit documents I already sent?
Yes, if they were lost or not previously considered. Explain when you sent them and how they support the disputed adjustment. Simply repeating evidence the IRS already evaluated does not establish a basis for reconsideration.
Does the request stop a levy or extend a court deadline?
The request itself does not automatically stop collection or extend a Tax Court, appeal or refund deadline. Address an urgent collection notice separately and confirm whether the IRS has actually granted a collection hold.
Can any accountant represent me before the IRS?
No. Representation depends on eligibility to practice and proper authorization. Attorneys, CPAs and enrolled agents generally have broad IRS representation rights; other preparers may have limited or no representation rights. Form 2848 must identify the representative, tax matters and periods covered.