What is IRS Letter 2357?

IRS Letter 2357 is sent in connection with an audit reconsideration request. Audit reconsideration is an IRS process that allows taxpayers to challenge the results of an audit (examination) after the audit is closed, when: (1) you did not participate in the original audit (you didn't respond to audit notices, didn't appear for the audit, or the audit was conducted by correspondence and you didn't reply), (2) you have new documentation that was not previously considered, (3) you believe the audit assessment contains a computational or procedural error, or (4) you have since filed an original return for a Substitute for Return (SFR) year. Letter 2357 may be: a response from the IRS after you submitted an audit reconsideration request, an IRS-initiated letter regarding a pending reconsideration, or a notice requesting additional information to process your reconsideration.

When should I request an audit reconsideration?

Request an audit reconsideration when: (1) you did not participate in the original audit and have evidence that the IRS's assessment is wrong, (2) the IRS assessed tax based on a Substitute for Return (SFR) and you have now prepared an original return showing a lower (or zero) liability, (3) you have new evidence that was not available during the original audit, (4) the IRS made a computational error in the assessment, (5) you believe the IRS auditor made a mistake of law or fact. Do NOT use audit reconsideration to re-argue issues already decided against you with the same evidence — that is an appeal, not reconsideration. Reconsideration requires new evidence or an error, not simply disagreement.

How do I request audit reconsideration?

Submit a written request to the IRS office that conducted the original audit (the address is on the audit report or the notice of deficiency). Include: (1) A cover letter explaining that you are requesting audit reconsideration for the tax year(s) in question, why you did not participate in the original audit (if applicable), and what new evidence you are providing. (2) A complete, signed copy of the tax return if you are challenging an SFR assessment. (3) All supporting documentation for the items in dispute (receipts, canceled checks, bank statements, contracts, 1099s, W-2s, etc.). (4) A copy of the audit report (Revenue Agent Report / 30-day letter / statutory notice of deficiency) with the items you are challenging clearly identified. (5) Any correspondence showing why you didn't participate in the original audit. Send everything by certified mail, return receipt requested.

Does audit reconsideration stop IRS collection?

No. Filing an audit reconsideration request does NOT automatically stop IRS collection actions. The IRS can continue to levy wages, bank accounts, and other assets while the reconsideration is pending. However, you can request that collection be suspended during the reconsideration by: (1) entering into an installment agreement, (2) requesting currently-not-collectible status, or (3) if the IRS has issued a final notice of intent to levy, requesting a Collection Due Process hearing (Form 12153), during which you can raise the audit reconsideration as part of your collection alternative argument. Paying the assessment first (or a portion) and filing a formal refund claim is sometimes the safest path if collection is imminent.

What is the difference between audit reconsideration and an IRS appeal?

An appeal (IRS Appeals Office) is the process for challenging an audit BEFORE it is finalized — you dispute the Revenue Agent's findings, present your arguments and evidence to an independent Appeals officer, and if you lose, you go to Tax Court. Audit reconsideration happens AFTER the audit is closed and the assessment is final — typically because you did not participate in the audit. Reconsideration is essentially a 'do-over' based on new evidence or an error. Key differences: (1) Appeals happens before assessment; reconsideration after assessment. (2) Appeals preserves Tax Court rights; reconsideration does not. (3) Appeals requires no new evidence; reconsideration typically does. (4) Appeals has a statutory framework; reconsideration is an administrative (discretionary) IRS program.

Audit Reconsideration

IRS Letter 2357: Audit Reconsideration

You missed your original audit — and now the IRS has assessed tax you believe is wrong. Audit reconsideration gives you a second chance to present evidence and challenge an assessment you didn't participate in. But you need new evidence, not just disagreement.

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Do You Qualify for Audit Reconsideration?

You did not participate in the original audit — you never responded to IRS correspondence, didn't attend the audit, or the IRS assessed tax after you moved and didn't receive the notices (the MOST common scenario)

You have NEW evidence — receipts, records, bank statements, contracts, or other documentation that was not available to or considered by the original auditor

The IRS prepared a Substitute for Return (SFR) for you and you have now filed the original return — which shows a lower (or zero) liability

The IRS made a mathematical or procedural error — the assessment calculation is wrong, the wrong tax rate was applied, or the IRS included income that wasn't yours

You never received the statutory notice of deficiency (90-day letter) — depriving you of your right to petition Tax Court

Frequently Asked Questions

How long does audit reconsideration take?

Audit reconsideration is not governed by a statutory timeline and can take 3-9+ months depending on the IRS office's workload, the complexity of the issues, and the completeness of your submission. Follow up periodically with the IRS and respond promptly to any requests for additional information.

Can I request reconsideration for multiple tax years?

Yes. You can request reconsideration for any number of tax years in a single request. Each year is considered independently, and you should provide complete documentation for each year separately. If the issues are the same across years, the same evidence may support all years.

What if my reconsideration is denied?

If reconsideration is denied, you still have options: (1) Pay the tax and file a formal refund claim (Form 843), then sue for refund in U.S. District Court or Court of Federal Claims. (2) Enter into an Offer in Compromise based on doubt as to liability (challenging whether you actually owe the tax). (3) Raise the reconsideration issues in a Collection Due Process hearing if the IRS later issues a final notice of intent to levy.

The IRS Audit Isn't Always Right — Challenge It with New Evidence

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