Direct answer
What is examination reconsideration?
Not automatically. We negotiate a separate hold while reconsideration is pending — often via TAS or hardship request.
Audit reconsideration is one of the most underused tools in the IRS playbook.
Proof
Does examination reconsideration actually work?
Yes — here's what the IRS's own data shows about examination reconsideration outcomes, timelines, and acceptance.
Process
How does the examination reconsideration process work?
In 4 defined steps: verify reconsideration is the right tool → build the reconsideration package → negotiate with the reconsideration examiner → coordinate collection holds. Most clients see protective action within days, with full resolution measured in weeks to months.
- 01
Verify reconsideration is the right tool
If a 90-day letter is still open, file Tax Court instead. If reconsideration was already denied, options narrow. We assess before filing.
- 02
Build the reconsideration package
Letter requesting reconsideration + new documentation + Form 12661 if needed + reconciliation showing the corrected liability.
- 03
Negotiate with the reconsideration examiner
Often a different examiner than the original — fresh review with new evidence.
- 04
Coordinate collection holds
Reconsideration doesn't automatically pause collection — we negotiate a hold separately.
Want to know if examination reconsideration is right for your case?
Free, confidential 15-minute case review with a CPA — no sales pressure, no obligation.
Timeline
How long does examination reconsideration take?
Most cases move through 3 phases. Expect protective relief in the first phase and full resolution typically in 3–9 months.
Eligibility & document review
Confirm reconsideration is correct path; gather new evidence.
Submission
Package filed with the appropriate IRS office.
IRS review
Examiner review and decision; possible Appeals.
Eligibility
Do I qualify for examination reconsideration?
Examination Reconsideration fits a specific set of taxpayer situations — and there are cases where a different strategy will get you a better outcome. Here's exactly who it's for and who it isn't.
Who this is for
- Taxpayers assessed by default (no response audit)
- Anyone with newly discovered documentation
- Cases where the original auditor disallowed legitimate items
When this isn't the right tool
- Liability was paid in full — reconsideration not available, file refund claim instead.
- Issue was litigated in Tax Court or Appeals — res judicata bars reconsideration.
- Liability resulted from a closing agreement or signed Form 906.
What we handle for you
- Evaluate eligibility and likelihood of reversal
- Prepare the reconsideration package
- Negotiate with the reconsideration examiner
Investment
How much does examination reconsideration cost?
We engage on a written flat fee with no hourly billing — typical engagements range from a few thousand to mid-five figures depending on the factors below. Your initial consultation is free and you receive a written quote before any commitment.
The fee for your case depends on:
- • Volume of new evidence to compile.
- • Whether collection holds must be negotiated in parallel.
- • Whether Appeals is required after reconsideration denial.
Your initial consultation is free. You'll get a written scope and flat-fee quote before any engagement.
Watch out
What mistakes should I avoid with examination reconsideration?
These are the four most common errors we see when taxpayers (or under-qualified preparers) handle these cases — each one can cost months of delay or trigger an outright rejection.
Filing reconsideration when Tax Court is still open
Tax Court provides independent review — reconsideration is discretionary. We file Tax Court when the 90-day window remains.
Submitting weak or unsubstantiated new evidence
Reconsideration is denied without material new information. We curate aggressively.
Compare
What are the alternatives to examination reconsideration?
Examination Reconsideration isn't the only path. Here are the other IRS programs that may fit better depending on your finances, asset picture, and timeline.
Doubt-as-to-Liability OIC
Liability is wrong but reconsideration isn't available — challenge via Form 656-L.
Refund claim (Form 843 / 1040-X)
Liability already paid — recover via refund claim.
Not sure which path fits your situation? We'll tell you straight.
Free, confidential 15-minute case review with a CPA — no sales pressure, no obligation.
More questions answered
Common questions about examination reconsideration
Direct answers to the 2 questions we hear most often from taxpayers researching examination reconsideration.
Will reconsideration stop collections?+
Not automatically. We negotiate a separate hold while reconsideration is pending — often via TAS or hardship request.
Can I request reconsideration on a Substitute for Return (SFR) assessment?+
Yes — and this is one of the most successful reconsideration scenarios. Filing the original return with proper deductions almost always reduces the SFR balance significantly.
Why Comprehensive Tax Resolution
Why should I hire Comprehensive Tax Resolution for examination reconsideration?
Your case is reviewed and led by Franklin Sofi, MBA, CPA, CTRS — backed by a flat-fee engagement, same-day Power of Attorney filing, and 16+ years of direct IRS representation.
- Founder Franklin Sofi, MBA, CPA — Certified Tax Resolution Specialist with 16+ years representing taxpayers before the IRS and ASTPS Gold Member.
- You never speak to the IRS. Power of Attorney (Form 2848) is filed the same day so every call, letter, and Revenue Officer is routed to our office.
- Flat-fee engagements with a written scope. No hourly surprises, no monthly retainers stretching out a case that should close.
References
Sources & further reading
Authoritative primary sources cited or referenced on this page.
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