Disagree with an IRS Tax Audit - Ask for Tax Audit Reconsideration - IRS can take a second look

Michael Sullivan Fresh Start Tax Expert

Disagree with an IRS Tax Audit – Ask for Tax Audit Reconsideration – Affordable Former IRS Who Agents Know System.  1-866-700-1040


As Former IRS Agents we know how to open up your case for a second look.

Over 65 years of direct IRS work experience.  We know the system. You can reduce your IRS Tax Debt and Settle.

If you will taxes is a result of the IRS letter reconsideration we will settle your tax debt at the same time.

Fresh Start Tax LLC can get your IRS Tax Audit reopened and more than likely greatly reduce your tax liability.

Former IRS agents with over 60 years with the IRS know the IRS system. You can take advantage of our 60 years of experience at the IRS.

Many times the Internal Revenue Service audits your tax return and you do not even know the tax audit took place.

Other times you simply disagree with the tax audit and you need the IRS to reopen the case again.

We can get your IRS Tax Audit re-opened by requesting a IRS Tax Audit Reconsideration



The Internal Revenue Service will re-open tax audits to:


  • Ensuring the amount of assessed tax is correct.
  • Ensuring the collection process is suspended while the reconsideration request is being considered.
  • Ensuring that the procedures support the abatement of assessments in appropriate situations.




What is the Definition of an Audit Reconsideration


An IRS Tax Audit Reconsideration is the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax credit was reversed.

If the taxpayer disagrees with the original determination he/she must provide information that was not previously considered during the original examination.

It is also the process the IRS uses when the taxpayer contests a Substitute for Return (SFR) determination by filing an original delinquent return.

Reasons to request an IRS Tax Audit Reconsideration:

Some reasons for an audit reconsideration request:

  • The taxpayer did not appear for the audit,
  • The taxpayer moved and did not receive the correspondence from the IRS,
  • A taxpayer might request an audit reconsideration also if you disagree with an audit assessment from an initial tax audit of his/her return.



If the IRS prepared your Tax Return under 6020B:


The taxpayer can disagree with a tax assessment created under the authority of IRC Section 6020(b), Substitute for Return (SFR) you can also request a tax audit reconsideration.

You can also qualify if you have been denied tax credits such as EITC claimed, during prior examination.

Criteria for Reconsideration


In order to request an IRS Tax audit reconsideration:


  • The taxpayer must have filed a tax return.
  • The assessment remains unpaid or the Service has reversed tax credits that the taxpayer is disputing.
  • The taxpayer must identify which adjustments he/she is disputing.
  • The Taxpayer must provide additional information not considered during the original examination.


Information the Taxpayer should provide


  • All information received from the Taxpayer pertinent to the issue
  • Information not considered during the original audit.
  • Copies of letters and reports received by the taxpayer, if the case is NOT on RGS.
  • Copies of documents already submitted by the taxpayer.
  • Amended return, if applicable.


Tax Authority for the IRS to accept a Reconsideration

The Internal Revenue Service has the discretionary authority to abate an assessment of any tax if it is excess of the taxpayer’s liability per IRC Section 6404(a) (301.6404-1) .


Acceptance of Request


A request for reconsideration will be considered if:


  • The taxpayer requests the abatement of an assessment based on information that was not previously considered which, if considered, would have resulted in a change to the assessment.
  • An original delinquent return is filed by the taxpayer after an assessment was made as a result of a return executed by the IRS under IRC Section 6020(b) or other substitute for return procedures.
  • There was an IRS computational or processing error in assessing the tax.



Non-Acceptance of Request


A request for reconsideration will not be considered if:

The taxpayer has already been afforded an audit reconsideration request and did not provide any additional information with his/her current request that would change the audit results.


Other pertinent information


  • The assessment was made as a result of a compromise under IRC Section 7122. These agreements are final and conclusive.
  • The assessment was made as the result of final TEFRA administrative proceedings.
  • The assessment was made as a result of the taxpayer entering into an agreement on Form 870-AD, “Offer of Waiver of Restrictions on Assessment and Collection of Deficiency in Tax” .
  • The United States Tax Court has entered a decision that has become final, or a District Court or the United States Court of Federal Claims has rendered a judgment on the merits that has become final.


Noteworthy Facts:

Any request for reconsideration on cases that were settled by Tax Court, District Court, or Court of Federal Claims should be forwarded to the Office of the Associate Area Counsel for forwarding to the docket attorney.

When the Tax Court dismisses a case for lack of jurisdiction, it does not enter a decision and the case is not dismissed on the merits.

See IRC Section 7459(d). Likewise, when a District Court or the United States Court of Federal Claims dismisses a case for lack of jurisdiction, the case has not been dismissed on the merits.

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*Mr. Sullivan has been in private practice since 1982 in South Florida which gave roots to Fresh Start Tax LLC.
The firm began as Sullivan & Powell PA and through the years transitioned to its now current form.

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