Short answer
Audit reconsideration is the IRS process for reopening an audit, or a return the IRS prepared for you, when the tax is still unpaid. You send a letter, ideally with Form 12661, and copies of new documents to the office that did the audit. Publication 3598 sets no deadline while the balance remains unpaid.
Key takeaways
- You qualify if the assessment is unpaid and you have new information, a return to replace an IRS-prepared one, or proof of an IRS computational error (IRM 4.13.1.2.1).
- It is not available after full payment (file a refund claim instead), a closing agreement, an accepted offer in compromise, a Form 870-AD settlement or a final court decision.
- No special form is required: a letter, copies of new documents and, ideally, Form 12661. The IRS aims to answer within 30 days, but it can take months.
- The IRS may delay collection once it has your documents, but not if you only call, if you are on an installment agreement, or if less than a year remains on the collection statute.
- If the IRS denies the request, you can go to Appeals or pay and claim a refund; interest keeps running either way.
What audit reconsideration is and when it applies
IRS Publication 3598 describes audit reconsideration as the process the IRS uses “to help you when you disagree with the results of an IRS audit of your tax return, or a return created for you by the IRS because you did not file.” The IRS manual (IRM 4.13.1.2, revised December 10, 2025) narrows it to assessments that “remain unpaid,” or tax credits that were reversed. You must bring new information the original audit did not consider, file an original return to replace an IRS-prepared one, or show an IRS computational or processing error.
Publication 3598 lists the usual reasons people ask:
- You did not appear for the audit or did not send the documents requested.
- You moved and never received the IRS letters.
- You have information you did not provide during the audit.
- You disagree with the assessment from the audit.
Audit reconsideration usually starts with a bill. A CP14 after an audit is common. Other starting points are an assessment based on an IRS-prepared return that followed a CP2566, or one that followed a CP2000 and a CP3219A notice of deficiency you did not answer in time. If you still hold an unexpired notice of deficiency, the Tax Court petition is usually the stronger route, because reconsideration only begins after the tax is assessed. Our guide to disputing an IRS balance compares all the routes.
Who qualifies, and when the IRS will say no
IRM 4.13.1.2.1 sets the criteria. You must have filed a return, the assessment must be unpaid (or the dispute is over reversed credits), and you must identify the adjustments you dispute. You also need either new information or an IRS computational or processing error. Publication 3598 and IRS Policy Statement 3-15 list the cases that cannot be reopened.
| Your situation | Audit reconsideration? | What to do instead |
|---|---|---|
| You missed the audit but now have documents | Yes | Send the request with the new documents |
| The IRS prepared a return for you and you now file your own | Yes (an SFR reconsideration) | Send a signed original return; unsigned returns are sent back |
| The IRS made a computational or processing error | Yes | Explain the error and attach proof |
| You already paid the assessment in full | No | A refund claim, usually Form 1040-X |
| You signed a closing agreement (Form 906) or the IRS accepted your offer in compromise | No | These agreements are final |
| You settled with Appeals on Form 870-AD | No | Generally final |
| The Tax Court or another court made a final decision on the tax | No (a dismissal for lack of jurisdiction is an exception) | None through the IRS |
| The tax came from final partnership (TEFRA) adjustments | No | None through this process |
| You disagree with a math-error correction | Not this process | Request abatement within 60 days of the notice |
| The audit is still open and nothing has been assessed | Not yet | Respond to the examiner handling the audit |
Sending documents the IRS already reviewed will not change the result; resend them only if the IRS’s list of what it considered leaves them out. The IRS considers “each issue separately based on the new information that you provide.” IRM 4.13.1 covers individual Form 1040 audits; reconsideration of business returns follows other IRS procedures, so ask the office that did the audit.
How to request audit reconsideration, step by step
There is no required form and, according to Publication 3598, no deadline while the tax remains unpaid: a request “can be made anytime after an examination assessment has been made on your account and the tax remains unpaid.” Documentation must come with it.
- Find the audit report and mark each disputed item. Review the examination report (Form 4549) and its attachments and list every adjustment you think is wrong. If you can’t find the report, call the IRS or visit a Taxpayer Assistance Center.
- Gather new documents for that tax year. Collect documents the auditor did not see, such as receipts, bank statements, canceled checks or Forms 1099, for the year in question. Make copies; the IRS does not return originals.
- Write a letter, and use Form 12661 if it helps. Explain each disputed item and why. Form 12661, Disputed Issue Verification, has a block per issue for the amount you claimed, the amount the audit allowed and your reason. Number each document to match its issue.
- Add a copy of the report and your contact details. Include a copy of Form 4549 if you have it, plus a daytime and evening phone number and the best time to call. If you fax, put your taxpayer ID number and the tax year on every page.
- Send it to the right office. Upload through the IRS Document Upload Tool if your audit letter offers it, or fax or mail it to the office on your audit letter. For an IRS-prepared return, send your signed original return. For a CP2000 assessment, use the address on the CP2000.
- Keep proof and follow up. Keep copies of everything and proof of mailing. Answer any IRS request for more information within 30 calendar days so collection does not resume.
If the office that did your audit is not listed in Publication 3598 or on your letter, the IRS says to call 866-897-0161 or 866-897-0177 for the right address. To reach someone about a lost report, individuals can call 800-829-1040 (IRS.gov, 2026). Form 12661 is still the October 2015 revision, and the IRS recommends it but does not require it.
What happens to collection while the IRS reconsiders
Collection does not stop automatically. Publication 3598 says that when the IRS receives your documentation, “we may delay our collection activity,” but it “may resume collection activity if the documentation is not sufficient to support your position and you do not respond to any requests for additional information within 30 calendar days.” The IRS manual adds detail:
- A phone call is not enough. If you call without sending documents, IRS staff are told not to place a collection hold and to tell you collection “will continue until we receive the requested documentation” (IRM 4.13.1.3.3).
- No hold in some cases. A hold is not placed if less than one year remains on the collection statute or if you are on an installment agreement. Keep making your plan payments; Publication 3598 says you “must continue to make payments.”
- Revenue officer cases. If a revenue officer has your account, the reconsideration unit coordinates with that officer.
- Interest continues. Interest accrues at the federal short-term rate plus 3 percentage points, reset quarterly (7% (IRS.gov, Jul-Dec 2026) this quarter), on any part of the tax that is upheld.
Timeline and possible outcomes
Publication 3598 says you “should expect to hear from us” within 30 days. The IRS correspondence-audit page warns it may take several months. Under the IRS manual, if a full answer is not ready within 30 days, the IRS sends an interim letter giving a date when you can expect a resolution. The IRS may write asking for more information. You can check status in your IRS Online Account or by calling the number on your letter, and the Taxpayer Advocate Service can help with significant delays.
The IRS will tell you that it:
- accepted your information and will abate (remove) the tax;
- accepted it in part and will reduce the tax; or
- found it does not support your claim, so the assessment stands.
If you agree with what is left, pay it or set up a plan. If you owe $50,000 (IRS.gov, July 2026) or less, you can usually set up a Simple Payment Plan (formerly the streamlined installment agreement) without a financial statement; see IRS payment plans compared.
If the IRS denies your request
Publication 3598 gives three choices if you disagree with the result: request an Appeals conference, pay in full and file a formal claim, or do nothing and receive a bill.
- Appeals. The denial letter explains your appeal rights. Under IRM 4.13.1.4.18, the IRS forwards a case to the Independent Office of Appeals when it was accepted for reconsideration and denied in full or in part. It does not forward cases it never accepted or cases where you missed a scheduled appointment. While the case is in Appeals, the IRS letter says collection “will not be pursued,” but interest and penalties continue; you may make voluntary payments to limit them.
- Pay and claim a refund. Pay the tax and file a refund claim, usually Form 1040-X, within 3 years from when the return was filed or 2 years from when the tax was paid, whichever is later (IRC 6511(a)). If the IRS disallows the claim, you can file a refund suit in court.
- Collection Due Process. If you never received a notice of deficiency for the tax and had no other chance to dispute it, a CDP hearing after a final levy notice such as an LT11 can consider the amount itself (IRC 6330(c)(2)(B)).
- Doubt as to liability. Publication 3598 also points to an offer in compromise based on doubt as to liability (Form 656-L).
If the tax is right but you cannot pay it, compare your Fresh Start options.
Doing it yourself, free help, and when to hire a professional
Many reconsiderations are paperwork problems a taxpayer can handle alone: a missing receipt, a 1099 that was already reported, or a return you never filed. Professional help is more useful when several years are involved, when business income or expenses were disallowed, when the IRS-prepared return covers self-employment income, or when you are heading to Appeals.
- Taxpayer Advocate Service. Free help if the problem causes financial hardship or normal IRS channels have failed: 877-777-4778 (IRS.gov, 2026) or taxpayeradvocate.irs.gov.
- Low Income Taxpayer Clinics. LITCs represent eligible taxpayers in audits, appeals and collection matters, for free or a small fee.
- A representative. An enrolled agent, CPA or attorney can handle the request for you under a Form 2848 power of attorney.
Global Gate Tax Relief offers a free consultation and reviews your IRS transcripts before saying whether reconsideration is worth pursuing. If it takes the case, it quotes a flat fee upfront and makes no promises about the result. Start a free case review or call 1-877-800-8180.
Frequently asked questions
Not while the tax is unpaid. Publication 3598 says a request can be made any time after the audit assessment while the tax remains unpaid. Once you pay in full, the route becomes a refund claim, which has its own deadline: 3 years from filing or 2 years from payment, whichever is later.
No. The IRS does not require a special form, but it recommends Form 12661, Disputed Issue Verification, to explain each issue. A clear letter with copies of new documents is the minimum.
Not automatically. The IRS may delay collection once it receives your documents, and resumes if they are insufficient and you don’t answer a request for more information within 30 calendar days. No hold is placed if you only phone, if you are on an installment agreement (keep paying) or if less than a year remains on the collection statute.
Publication 3598 says to expect to hear from the IRS within 30 days of your request. The IRS also warns that a decision may take several months. If it cannot finish in 30 days, it should send an interim letter with an expected date.
No. If you paid the assessment in full, the IRS treats your request as a claim for refund. Individuals usually file Form 1040-X within 3 years of filing the return or 2 years of paying the tax, whichever is later.
Generally no. The IRS will not reopen tax that a court finally decided, or tax settled by a closing agreement, an accepted offer in compromise or a Form 870-AD agreement with Appeals. A Tax Court case dismissed for lack of jurisdiction is an exception and can be considered.
Yes. Not receiving IRS correspondence because you moved is one of the reasons Publication 3598 lists for requesting audit reconsideration. Send your documents with the request and update your address with the IRS.
Sources
- IRS Publication 3598, What You Should Know About the Audit Reconsideration Process (Rev. 11-2023)
- IRM 4.13.1, Examination Audit Reconsideration Process (12-10-2025)
- IRM 1.2.1.4.15, Policy Statement 3-15, Reconsideration of an Unpaid Assessment
- IRS: Audit reconsideration process for correspondence examination (audits by mail)
- Taxpayer Advocate Service: Audit reconsiderations
- IRS Form 12661, Disputed Issue Verification (Rev. 10-2015)
- IRS: Understanding your CP3219A notice
- IRS: Understanding your CP2566 notice
- IRS: File an amended return
- 26 U.S.C. 6330, Notice and opportunity for hearing before levy
- 26 U.S.C. 6511, Limitations on credit or refund
- IRS: Low Income Taxpayer Clinics
- IRS: Quarterly interest rates
We check every figure against IRS.gov and log changes on the key figures page.
Want a professional to look at your options?
Free consultation, no obligation. If we take your case, the flat fee is quoted upfront before any work begins. If you can handle it yourself through IRS.gov, we will tell you. No outcome is guaranteed.
This page is general information about IRS rules, not tax or legal advice for your situation. IRS figures change; each one links to its official source and the date we last checked it.