Audit Reconsideration Process

Audit Reconsideration — It Isn't Over Until We Say It's Over

A client walks in with an assessment from an audit they didn't respond to, didn't understand, or lost without representation. The 90-day window is gone. Collections is moving. The question isn't whether the original result was right — it's whether you can reopen it, and what it takes to get a different answer the second time around.

This program walks the audit reconsideration process from the threshold question forward. When reconsideration is the right tool versus when the case belongs in CDP, OIC doubt-as-to-liability, or Tax Court via a different door. What the IRM actually requires for IRS to accept a reconsideration request, and the records that move the needle versus the records that don't. How to organize and present documentation so the examiner reviewing the file can reach the conclusion you want without hunting for it. And the FOIA request — when to file one before you respond, what to ask for, and how the administrative file changes your strategy once you can see what the original examiner saw, wrote, and missed.

Who it's for: Experienced EAs, CPAs, and tax attorneys handling representation work, or practitioners adding it to their practice.

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*Self-Study recording not available for NASBA CPE credit.

IRS Program #: 7Q3WU-T-00907-26

CTEC Course #: 6248-CE-00255

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