Audit Reconsideration
Definition
Audit reconsideration is an IRS administrative process that allows a taxpayer to dispute an assessment made from an audit they did not attend, did not agree with, or have new documentation to support.
Why This Matters for Tax Relief
Audit reconsideration is not an appeal — it is an administrative request for the IRS to re-examine an assessment. It is most commonly used by taxpayers who received a notice of assessment from an audit they were unaware of (often a correspondence audit they never received), taxpayers who have documentation they did not provide during the original audit, and taxpayers who disagree with specific items assessed but cannot afford to petition Tax Court. To request reconsideration, the taxpayer submits a written request along with any supporting documentation to the IRS service center that issued the original assessment. There is no formal deadline for audit reconsideration, but the underlying liability continues to accrue interest and penalties while the request is pending. Audit reconsideration does not suspend IRS collection activity — a separate request for a collection hold or installment agreement may be needed in parallel.
2026 Update
The IRS has expanded its Automated Underreporter (AUR) program in 2026, increasing the volume of correspondence audits issued. Taxpayers receiving CP2000 notices (the most common form of automated audit) should understand that audit reconsideration is available if the initial response is rejected.
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Related Terms
CDP Hearing (Collection Due Process)
A Collection Due Process hearing is a formal taxpayer right under IRC § 6330 to appeal an IRS lien filing or proposed levy before an independent Appeals Officer, with the option to escalate to U.S. Tax Court if Appeals disagrees.
CAP Hearing (Collection Appeals Program)
A Collection Appeals Program hearing is a faster, less formal IRS appeals process for disputing rejected installment agreements, proposed lien filings, or levies — but unlike a CDP hearing, it does not provide Tax Court access.
Taxpayer Advocate Service (TAS)
The Taxpayer Advocate Service is an independent organization within the IRS that helps taxpayers resolve problems with the IRS and recommends systemic changes to prevent future problems.
Notice of Deficiency (90-Day Letter)
A Notice of Deficiency is a formal IRS determination that additional tax is owed, triggering a 90-day window during which the taxpayer may petition the U.S. Tax Court without first paying the disputed amount.