When reconsideration applies
You qualify if you didn't receive or respond to the original audit notice, you have new documentation, or there's an error in the assessed tax. Available even after the 90-day window for Tax Court has closed.
What to submit
Form 12661 with supporting documents explaining why the assessment is wrong. The IRS sends the file back to the examination team or a new examiner to review.
Common questions
- How long does reconsideration take?
- 6-12 months typically. Collection may continue during the process unless we negotiate a hold.
Related
IRS Audit Representation
Herman Viglione, EA, represents taxpayers in IRS and state audits. Correspondence, office, and field audits handled remotely for clients in any state.
Tax Relief & Back Taxes
Back tax filings, installment agreements, penalty abatement, and offer-in-compromise support for taxpayers behind with the IRS. We file first, then negotiate.
Responding to an IRS Notice of Deficiency
The Notice of Deficiency (90-day letter) is your window to petition Tax Court without paying first. Pay, petition within 90 days, or the tax becomes final.