Audit reconsideration

Audit reconsideration is the process for asking the IRS to re-examine an assessment after an audit or a substitute for return when the taxpayer did not respond, moved, or has new information.

How it works

Audit reconsideration asks the IRS to re-examine an assessment made after an audit the taxpayer did not participate in, or a substitute for return, when there is new information. It is a written request with the documentation the IRS did not have. There is no deadline, but collection continues while the request is reviewed unless a separate hold is arranged, and refunds are limited by the refund statute.

Why it matters

Large balances from audits that were never contested, often because notices went to an old address, can sometimes be reduced years later.

Related: substitute for return. Read more: IRS audit defense.

Where this comes up in our work

Tax controversy attorneys

Audits, penalties, collections, criminal exposure, and Tax Court, handled by attorneys who do this every day.

See the practice page →

Have a question about this?

Our tax attorneys handle IRS audits, crypto tax, offshore disclosures, and opinion letters for clients nationwide. Consultations are confidential.

Definitions are general information, not legal advice, and may not reflect the most recent changes in law.