Summary
- Audit reconsideration may be a strong option when you have new or previously unsubmitted documentation.
- It is often used when you missed an audit or did not respond to IRS notices.
- It may not be effective if you already agreed to the audit results or do not have supporting evidence.
- Choosing the wrong strategy can delay resolution and may limit your options for addressing your tax liability.
If you disagree with the results of an IRS audit, audit reconsideration may seem like the obvious next step. But it is not always the right strategy.
In some cases, audit reconsideration can help reduce an incorrect tax assessment by giving the IRS information it did not previously consider. In others, pursuing reconsideration may delay resolution when another option would be more appropriate.
Understanding when audit reconsideration makes sense—and when to consider another strategy—is an important part of resolving an audit-related tax issue.
What Is Audit Reconsideration?
Audit reconsideration is an IRS process that allows certain taxpayers to request another review of an audit assessment after the audit has been completed.
It is commonly used when a taxpayer did not participate in the original audit, has documentation that was not previously considered, or believes the IRS made an assessment using incomplete information. In the right circumstances, reconsideration gives the taxpayer an opportunity to provide information that could change the audit results.
When Audit Reconsideration May Be the Right Strategy
You Missed the Original Audit
If you did not respond to IRS notices or otherwise did not participate in the original examination, the IRS may have completed the audit without important information from you.
For example, the IRS may have disallowed deductions or expenses because supporting records were never provided. Audit reconsideration may allow you to submit that documentation and ask the IRS to reevaluate the assessment.
You Have New Documentation
Documentation is one of the most important considerations in an audit reconsideration case. Receipts for previously disallowed expenses, bank statements, mileage logs, business records, and other supporting documents may provide the IRS with information it did not have during the original audit.
Simply disagreeing with the audit results is generally not enough. The goal is to provide information that supports why the assessment should be changed.
The IRS Made Its Decision Using Incomplete Information
Sometimes an assessment is based on information that does not tell the entire story. Third-party reporting, such as Forms W-2 or 1099, may establish income without accounting for deductions, expenses, or other relevant information.
This can be particularly important for self-employed taxpayers, business owners, and taxpayers whose liabilities were assessed without complete records. When additional documentation changes the picture presented during the original audit, reconsideration may provide a way to address the assessment.
You Still Owe the Assessed Tax
Audit reconsideration generally concerns unpaid assessments resulting from an examination. If the additional tax remains outstanding and you otherwise meet the IRS requirements, reconsideration may provide an opportunity to challenge some or all of that assessment.
When Audit Reconsideration May Not Be the Best Option
Audit reconsideration is not appropriate for every audit dispute. Before pursuing it, it is important to determine whether the IRS will consider the request and whether another procedure better fits the circumstances.
You Already Agreed to the Audit Results
If you signed an agreement accepting the audit findings, requesting reconsideration may be more complicated. The documents you signed and the procedural history of the case can affect what options remain available.
Before attempting to reopen the issue, it may be important to determine whether another administrative or legal remedy applies.
Your Case Has Already Gone Through Appeals
The history of the case also matters. If the disputed issues have already been considered through the IRS Independent Office of Appeals or another formal process, audit reconsideration may not be available for those same issues.
At that stage, the appropriate next step will depend on what occurred previously and where the case currently stands.
You Do Not Have Additional Supporting Evidence
One of the biggest obstacles to a successful reconsideration request is a lack of documentation. Sending the IRS the same information it already reviewed generally does not give it a reason to change the assessment.
Before pursuing reconsideration, taxpayers should identify what evidence supports a different result and whether the IRS previously considered that evidence.
The Real Issue Is Paying the Balance
Sometimes the audit assessment itself is accurate, but the resulting tax bill is unaffordable. In that situation, repeatedly challenging the audit may not address the actual problem.
Collection alternatives such as an installment agreement, partial payment installment agreement, offer in compromise, or currently not collectible status may be more relevant when the primary concern is the ability to pay rather than the accuracy of the assessment.
Alternatives to Audit Reconsideration
If audit reconsideration does not fit your situation, that does not necessarily mean you are out of options.
An IRS appeal may be available when you are still within the applicable deadline and disagree with the IRS’s determination. Because appeal rights can be time-sensitive, taxpayers should pay close attention to the deadlines listed on IRS notices.
If the tax assessment is correct but paying the full amount would create a financial hardship, an IRS payment or resolution option may be more appropriate. Depending on the circumstances, this could include an installment agreement, partial payment installment agreement, offer in compromise, or currently not collectible status.
Penalty abatement may also be worth considering when penalties make up a significant portion of the balance. Eligibility depends on the type of penalty and the taxpayer’s circumstances.
How to Decide Which Strategy to Use
The appropriate strategy depends on more than whether you disagree with the amount the IRS says you owe. The timeline of your case, the documentation available, what happened during the original examination, previous appeals or agreements, and your current financial circumstances can all affect which options are available.
For example, a taxpayer with strong documentation that was never considered during an audit may be in a very different position from someone who agrees with the assessment but cannot afford to pay it.
That is why tax resolution rarely has a one-size-fits-all solution.
Why Strategy Matters
Choosing a procedure that does not fit your circumstances can cost valuable time while interest and, when applicable, penalties continue to accrue. It can also cause taxpayers to miss deadlines or focus their efforts on disputing an assessment when the more immediate issue is resolving collection.
Determining where the case currently stands—and what options are actually available—can help create a clearer path toward resolution.
Professional Guidance Matters
Audit reconsideration involves more than simply resubmitting paperwork. A tax attorney can review how the original assessment occurred, evaluate the available documentation, determine whether reconsideration is appropriate, identify other potential resolution strategies, and communicate with the IRS on your behalf.
At McClure & Stewart, we help clients evaluate their circumstances and determine an appropriate strategy for addressing IRS audit and collection issues.
If you are in Utah and dealing with an IRS audit assessment, contact our office today for a free consultation.
FAQs
No. Whether reconsideration is appropriate depends on the history of the audit, the evidence available, applicable deadlines, and what you are trying to resolve. In some cases, another administrative or collection option may be more appropriate.
Supporting documentation is generally an important part of an audit reconsideration request, particularly when the IRS did not previously consider the information.
An agreement to the audit results can affect whether reconsideration is available. The specific documents signed and procedural history should be reviewed before determining what options remain.
Audit reconsideration may still be available in some circumstances even after an appeal deadline has passed, depending on the facts of the case and IRS requirements.
Potentially. Depending on the circumstances, other administrative, collection, or payment options may remain available
Resources
IRS Audit Reconsideration Process
MaKenna is the Administrative Assistant at McClure & Stewart Tax Resolutions, where she supports client communications and assists with day-to-day operations. Since joining the firm in March 2025, she has also contributed to the company’s marketing efforts, including writing blog content, managing social media, and helping coordinate advertising.
She is currently pursuing a degree in marketing, with a focus on content strategy and digital outreach. MaKenna is passionate about clear communication and helping clients feel informed and supported throughout the tax resolution process.