Audit Reconsideration

Audit reconsideration can be a viable action to eliminate an IRS tax liability that has been unfairly assessed without full consideration of the facts.  It is always advised to contact tax professional when defending IRS assessments.  Our tax professionals have sufficient experience to assist in eliminating, in whole or in part, our clients’ IRS liabilities.  Below you will find information regarding the Audit reconsideration process.

signing the transaction

IRS will only reconsider a previous audit if:

  1. New Information is submitted that, if accepted, would change the tax liability;
  2. Filed a Return after the IRS completed a substitute return;
  3. IRS made a Computational Error in the assessment; or
  4.  Liability is Unpaid or Credits are denied.

IRS will Deny an Audit Reconsideration if:

  1. Closing Agreement has been entered (FORM 906);
  2. Offer in Compromise reached;
  3. Agreement with Appeals (FORM 870-AD);
  4. Amount Due is a result from a FPAA under the TEFRA statute; or
  5. A Court has ruled on a Final Determination.

Procedure to File an Audit Reconsideration Request:

  1.  File a Tax Return (if not previously done);
  2.  Formal Letter identifying the changes;
  3.  Include Supporting Documentation (Form 4549 & add’l docs); and
  4.  Include Contact Information and Convenient Time to Call.

What to Expect:

  1.  Collection Activity will cease if Request is Sufficient for Review;
  2.  Adjustments will be made if necessary; and
  3. Continue to Pay Installment during Reconsideration

If Assessment still NOT correct:

  1.  Request Conference with Appeals Office; and
  2.  Formal Letter requesting appeal


Pay amount due and file a Refund Suit in the US Court of Federal Claims (File within 2 years or after 6 months if no response on Audit Reconsideration)

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