What Is an Audit Reconsideration and When Should You Request One?

Desk with paperwork

Sometimes the IRS closes an audit with changes you never agreed to. Maybe you didn’t respond to the examination report. Maybe you missed the 30-day letter deadline. Maybe the IRS assessed tax based on a substitute for return (SFR) because you never filed. In any of these situations, the assessment stands — but you may have a path to reopen it through an audit reconsideration.

What Audit Reconsideration Is

An audit reconsideration is a process under IRM 4.13 where the IRS reviews the results of a prior audit when you have new information or documentation that wasn’t previously considered. It’s not an appeal. It’s a request for the IRS to take another look at the case using evidence that could change the outcome.

This applies to cases where the audit was closed — either because you defaulted (didn’t respond) or because the IRS assessed tax based on a substitute for return. It does not replace your appeal rights if you’re still within the appeal period.

When It Makes Sense

Audit reconsideration is appropriate when you have documentation that supports your original position but wasn’t provided during the exam — receipts, bank statements, contracts, or records that prove income was reported correctly or expenses were legitimate. It’s also appropriate when the IRS made an error in applying the law or calculating the adjustment, or when you filed a return after the IRS assessed tax based on an SFR.

What You Need to Submit

You’ll need to submit a written request explaining why you’re requesting reconsideration, along with all supporting documentation for the issues being reconsidered. If you filed a return after an SFR assessment, include a copy of the return with all schedules and supporting documents. The IRS will assign the case to an examiner who will review your submission and determine whether the original assessment should be adjusted.

What It Won’t Do

Audit reconsideration doesn’t stop collection activity while the case is being reviewed. If you have a balance due and the IRS is actively collecting, a reconsideration request doesn’t pause that process unless you specifically request it and the IRS agrees. You may need to address the collection side separately while the reconsideration is pending.

It also doesn’t guarantee a different result. If you submit the same documentation the IRS already had, or if the documentation doesn’t support your position, the assessment will stand.

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If you have an IRS assessment from an audit you didn’t respond to — or from a substitute for return — and you have documentation that could change the outcome, schedule a consultation to discuss whether an audit reconsideration is the right path. Learn more about our IRS representation services.