Audit Reconsideration
An Audit Reconsideration is an administrative process with the Internal Revenue Service where taxpayers can dispute the results of an audit after a final assessment has been made. This process is helpful for taxpayers who missed their deadline to file a Petition in U.S. Tax Court in response to a Notice of Deficiency. IRS Publication 3598 summarizes the Audit Reconsideration process.
The IRS will generally only consider an Audit Reconsideration request for one or more of the following reasons:
- The Taxpayer did not appear or respond to the underlying IRS audit;
- The Taxpayer moved and did not receive correspondence from the IRS regarding the underlying audit;
- The Taxpayer has additional information to present to the IRS that was not available or provided during the original audit; or
- The Taxpayer disagrees with the assessment resulting from the original audit.
Once an Audit Reconsideration claim is filed, the IRS will either accept the Taxpayer's requested changes (in full or in part) or reject the requested changes. If an Audit Reconsideration claim is rejected, a taxpayer can file an administrative appeal with the IRS Office of Appeals. Because Audit Reconsideration is an administrative process, the determination by the IRS Office of Appeals is final and cannot be challenged further in court.
Our tax attorneys are experienced in representing both individuals and businesses before the IRS in Audit Reconsideration claims. We invite you to contact us to schedule a consultation with a tax attorney.
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Results
We are committed to delivering results for our clients. We invite you to review a sample of Audit Reconsideration cases that we have successfully resolved for our clients. All cases are different and the summaries below should not be interpreted as a prediction or guarantee of success or specific results.
Audit Reconsideration – Tax Assessment Reduced by Over $150,000
The Taxpayer was audited and the IRS determined that the Taxpayer did not report taxable income from the sale of their home. The Taxpayer did not respond to the audit and did not file a Petition in U.S. Tax Court after the IRS issued a Notice of Deficiency. DeWitt Law represented the Taxpayer before the IRS and filed an Audit Reconsideration claim challenging the tax assessment. The IRS reversed the…
Audit Reconsideration – Tax Assessment Reduced by Over $92,000
The Taxpayer was audited but never received letters or correspondence from the IRS regarding the audit or the resulting Notice of Deficiency. DeWitt Law represented the Taxpayer before the IRS and filed an Audit Reconsideration claim challenging the tax assessment. The IRS reversed the assessment, which lowered the tax assessment by over $92,000.
Audit Reconsideration – Tax Assessment Reduced by Over $144,000
The Taxpayer was audited and the IRS disallowed substantial gambling loss deductions. The IRS issued a Notice of Deficiency but the Taxpayer did not file a Petition in U.S. Tax Court. DeWitt Law represented the Taxpayer before the IRS and filed an Audit Reconsideration claim challenging the tax assessment. The IRS reversed the assessment, which lowered the tax assessment by over $144,000.
Audit Reconsideration – Reversed Assessment
Client failed to respond to an IRS audit for tax year 2011 and $93,567 in additional tax ($168,516 with penalties and interest) was assessed. Because Client did not respond to the audit, file a timely appeal with the IRS, or file a Petition in U.S. Tax Court, the IRS took collection action against Client, including levy and garnishment. Client then hired DeWitt Law for representation. An audit reconsideration claim was…
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