IRS Audit Reconsideration Explained in Plain English: When It Applies, How It Works, and What Usually Happens

Getting an IRS audit notice — or realizing the IRS changed your tax return and now says you owe money — can feel overwhelming. Many people assume once the IRS decides something, that decision is final.

In reality, that’s not always true.

If the IRS assessed additional tax because of an audit or missing information, and you now have new documents or facts, you may be able to ask the IRS to take another look. That process is called audit reconsideration.

This page explains audit reconsideration in plain English — when it applies, when it doesn’t, how it works, and what usually happens next.

What Is IRS Audit Reconsideration?

Audit reconsideration is a process that allows the IRS to review a completed audit again when new information becomes available.

It is most often used when:

• The IRS increased your tax because you didn’t respond to an audit or document request
• The IRS disallowed deductions, credits, or income reporting due to missing paperwork
• You now have records that were not previously provided or considered

Audit reconsideration is not a new audit. It is a request to review the original audit results using additional information.

When Audit Reconsideration Usually Applies

Audit reconsideration is commonly used after situations involving:

• CP2000 notices (proposed changes from income mismatches)
• CP3219A notices (Statutory Notice of Deficiency)
• Audits where the IRS used third-party data because no response was received
• Audits completed while the taxpayer moved, was sick, or never received mail

In many cases, the IRS assumed income was taxable or deductions were invalid simply because documentation was missing. Audit reconsideration exists to correct that.

Common Reasons People Request Audit Reconsideration

1. You Never Received the Original Audit Letters

This happens more often than people think. Address changes, mail delivery issues, or certified letters not picked up can lead to audits being completed without the taxpayer ever responding.

If the IRS audited you without your participation, audit reconsideration may be appropriate.

2. You Had the Documents — Just Not at the Time

Life happens. Records get misplaced, accountants change, or documents are found later. If you now have proof supporting your original tax return, the IRS may consider it.

3. The IRS Used Incomplete or Incorrect Information

CP2000 audits often rely on income documents like 1099s and W-2s. They do not always account for business expenses, basis, or timing differences unless documentation is provided.

When Audit Reconsideration Does NOT Apply

Audit reconsideration is not available in every situation. It generally does not apply if:

• You agreed to the audit results and signed a closing agreement
• You already went to Tax Court and received a final decision
• You are simply unable to pay (payment issues are handled separately)

If the issue is affordability rather than accuracy, options like an IRS payment plan or collection relief may be more appropriate.

How Audit Reconsideration Is Requested

Audit reconsideration is not an online form or a phone call. It is a written request sent to the IRS with supporting documentation.

Most requests include:

• A written explanation of why you disagree with the audit results
• Copies of documents supporting your position
• A copy of the audit report or notice, if available

The IRS reviews the information and determines whether changes are warranted.

What Usually Happens After You Request Audit Reconsideration

The process is slow. There is no instant confirmation or online tracker.

Typical timelines range from several weeks to several months, depending on:

• The complexity of the audit
• The amount of documentation submitted
• Current IRS workload

During this time, collection activity may continue unless addressed separately. This is why it’s important to understand how audit reconsideration fits into the larger IRS process.

How Audit Reconsideration Connects to IRS Collections

Many people don’t discover audit reconsideration until after receiving:

• CP501 or CP503 balance due letters
• CP504 final balance notices
• Final Notice of Intent to Levy

At that point, the IRS considers the tax assessed and legally collectible. Audit reconsideration does not automatically stop levies or liens.

That’s why timing matters.

Audit Reconsideration vs. Appeals vs. Tax Court

Audit reconsideration is often confused with appeals. They are not the same.

• Audit reconsideration reviews completed audits using new information
• Appeals challenge audit results before they become final
• Tax Court disputes statutory notices before assessment

If you received a CP3219A or Letter 1058, timing becomes critical.

Does Audit Reconsideration Mean the IRS Was “Wrong”?

Not necessarily.

In many cases, the IRS made a reasonable decision based on the information it had at the time. Audit reconsideration simply allows additional information to be reviewed.

Sometimes the tax is reduced. Sometimes it stays the same. Occasionally it increases.

There are no guarantees — only a second review.

What Happens If Audit Reconsideration Is Denied?

If the IRS does not change the audit results, the tax remains owed. At that point, the focus usually shifts to resolution options such as:

• Payment plans
• Collection Due Process hearings
• Preventing levies on wages or bank accounts

Understanding Collection Due Process rights becomes important if enforcement action is underway.

Key Takeaways

• Audit reconsideration allows the IRS to review completed audits with new information
• It is common after CP2000 and non-response audits
• It does not automatically stop collections
• Timing and documentation matter

If you’re unsure what stage you’re in, start with understanding what your IRS letter means.

Educational purpose only. This site is not affiliated with the IRS or any government agency.