Have a Question? Search the Tax Rep Vault
TAX REP VAULT Exclusive Area
- Tax Rep Vault Home
- Critical Tax Cases
- Top Tax Q&As
< All Topics
Print
What situations disqualify someone from audit reconsideration?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
You generally cannot request reconsideration if:
– The full tax has been paid,
– You signed a closing agreement agreeing to the amount, or
– The U.S. Tax Court issued a final ruling on the liability.
If the tax has been paid, the taxpayer has two years to file a refund claim if they wish to challenge the liability.
-
Challenging an Assessed Tax
- What are common reasons taxpayers dispute an assessed IRS tax debt?
- When can a taxpayer request audit reconsideration?
- What situations disqualify someone from audit reconsideration?
- What must be included in an audit reconsideration request?
- What happens after an audit reconsideration is submitted?
- Can collection activity be paused during audit reconsideration?
- What is a Collection Due Process (CDP) hearing?
- When must a taxpayer raise their liability issue during a CDP process?
- How does a taxpayer request a CDP hearing?
- What should be written in Box 8 of Form 12153 for a liability dispute?
- What is a Doubt-as-to-Liability Offer-in-Compromise (DATL-OIC)?
- What form is used to submit a DATL-OIC?
- When is a DATL-OIC appropriate?
- What must be included with a DATL-OIC?
- Can a DATL-OIC offer be $0?
- What happens if a DATL-OIC is rejected?
- Why must taxpayers stay in compliance during a DATL-OIC process?
- What is Innocent Spouse Relief?
- What form is used for Innocent Spouse Relief?
- What are the three types of Innocent Spouse Relief?
- What determines eligibility for 6015(b) relief?
- What are the key qualifications for 6015(c) Separation of Liability?
- When is 6015(f) Equitable Relief used?
- Is there a time limit for requesting 6015(f) relief?
- What factors does the IRS consider under 6015(f)?
- Can tax returns filed without one spouse's consent be challenged?
- What is tacit consent?
- What is the IRS's position on forged signatures and innocent spouse claims?
- What is the difference between an erroneous item and an underpayment?
- Which types of relief are available for erroneous items?
- Which relief applies to underpayment cases?
- Why is supporting documentation crucial for Innocent Spouse Relief?
- What supporting documents are helpful for innocent spouse cases?
- What happens if a taxpayer is uncollectible during an Innocent Spouse claim?
- Can a taxpayer challenge a Notice of Deficiency they never received?
- How can automated notices lead to incorrect tax assessments?
- What role does IRS Appeals play in tax liability disputes?
- What should a tax practitioner do when a client disputes a liability in collection?
- What are 'automated under-reporter audits' and how do they impact taxpayers?
- What is the first method to challenge an incorrect tax debt?
- Show all articles (25) Collapse Articles