IRS Audit Reconsideration: How to Reverse an Audit Assessment After the Fact

Audit Reconsideration is an IRS administrative process under IRM 4.13.2 that allows taxpayers to dispute a prior audit assessment. It is not a formal appeal — it is a request for the IRS to re-examine the audit using new information. It is available when: you have new documentation not provided during the audit; you disagree with the IRS's analysis; or you did not receive audit notices and were assessed in your absence.

Any taxpayer can request audit reconsideration if: the tax from the audit has not been fully paid; you have documentation or arguments not previously considered; or the IRS made a computational error. There is no official deadline for requesting reconsideration, though the IRS is more receptive when the assessment is recent and collection is active.

Write a letter to the IRS Correspondence unit that handled the audit (address on your audit report) requesting reconsideration. Include: a copy of the audit report (CP2000 or examination report); your new documentation; and a clear explanation of what was wrong with the original determination. There is no official form — a clear, well-organized letter with documentation is sufficient.

The IRS assigns the reconsideration to an examiner who reviews your documentation and either: accepts your position and adjusts the assessment; partially accepts it; or denies reconsideration. If denied, you can appeal to the IRS Office of Appeals or request a meeting.

For returns where you have additional deductions or credits not claimed originally, an amended return (Form 1040-X) is often better than audit reconsideration. For audit-specific assessments where the dispute is about whether the IRS's examination findings were correct, audit reconsideration is the right path.