Responding to Adverse IRS Audit Assessments: Audit Reconsideration Requests, IRS Appeals, and Settlement Strategies

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, March 1, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar will provide tax advisers and professionals with a discussion of IRS exam hotspots, and will outline practical strategies for responding to unfavorable IRS audit results including requesting audit reconsiderations, navigating the IRS Appeals Process, and the litigation options available. The participants will learn how to effectively represent and negotiate with the IRS during the audit and through the reconsideration and/or appeal process.


Few events are as stress-inducing and potentially costly for a taxpayer as an adverse tax audit finding. While some IRS adjustments are justified, quite often adverse results arise from insufficient documentation, failure to properly respond to an Information Document Request (IDR), failure to file a required return, or lack of understanding by the IRS of its owns rules and regulations. The Internal Revenue Code provides many avenues for appeal and reconsideration, and tax advisers should know the various forums and procedures for challenging an audit determination.

Under certain circumstances, an Audit Reconsideration Request can be an appropriate and effective means of resolving a dispute with the IRS. Audit reconsiderations involve requesting the IRS to evaluate prior audit results by a revenue agent. Audit reconsiderations generally require that a taxpayer have new evidence, in the form of a new or corrected filing or additional documentation not previously submitted to the examining agent. An alternative approach to achieving a similar result is through the filing of an Offer in Compromise based on doubt as to liability, or the filing of a Request for a Collection Due Process Hearing.

The IRS appeals process also can provide a more beneficial and cost-effective means of resolving an adverse audit finding. Because appeals officers must consider the "hazards of litigation" in making a determination on a taxpayer's appeal, taxpayers often have a greater chance at achieving a favorable settlement in an IRS appeal due to the appeals officer's mandate to consider the defensibility in court of any assessment.

Listen as our authoritative panel provides a thorough review of the IRS audit process, and discusses best practices for advisers to determine what the best course of action is in responding to an adverse audit finding.



  1. Responses to initial IRS examination contact
  2. Responding to IDRs, and Requests for Taxpayer Interviews
  3. Statute of Limitations Issues During the Audit Process
  4. IRS Appeals Process-Strategies and Requirements
  5. Offers in Compromise Based Upon Doubt as to Liability
  6. Audit Reconsideration Requests
  7. Contesting Notices of Deficiency- Litigation Alternatives
  8. Collection Due Process Hearings


The panel will discuss these and other important questions:

  • How to respond to Information Document Request Form 4564
  • How to respond to IRS requests for taxpayer interviews
  • Strategies and Requirements for Audit Reconsideration
  • Under what circumstances should a representative advise the taxpayer to extend the statute of limitations
  • When is the IRS Appeals process beneficial for taxpayers?
  • What belongs in an Appeals Protest?
  • How has AJAC (Appeals Judicial Approach and Culture) changed the Appeals process?
  • When should a representative advise the filing of Petition with the U.S. Tax Court?


Bucci, Christin M.
Christin M. Bucci, Esq., CPA, LL.M.

Bucci Law Offices

Ms. Bucci focuses her practice on the successful resolution of federal and state tax controversies. She has extensive...  |  Read More

Brager, Dennis N.
Dennis N. Brager, Esq.

Certified Tax Specialist
Brager Tax Law Group

Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and...  |  Read More

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