Direct answer
Submitting an audit reconsideration request does not create an automatic statutory suspension of IRS collection. Publication 3598 says the IRS may delay collection when it receives the documentation, but may resume collection if the information does not support the position or the taxpayer does not respond to a request for more information within 30 calendar days.
Keep an installment agreement current
The IRS specifically instructs taxpayers with an existing installment agreement to continue making payments during audit reconsideration. Missing required payments can create a separate default problem even when the assessed liability is being disputed.
Interest and penalties can continue
Audit reconsideration reexamines the assessment; it is not a payment freeze. Interest and applicable penalties generally continue on an unpaid balance unless the IRS later reduces or removes the underlying tax or grants separate relief.
Do not miss a collection appeal deadline
A levy or federal tax lien notice may offer Collection Due Process or another appeal right with a deadline. Audit reconsideration does not substitute for Form 12153 or another required appeal request. File the correct collection response on time when the notice provides one.
When collection creates hardship
Contact the IRS office shown on the collection notice about payment options or a temporary collection delay. The Taxpayer Advocate Service may consider an unresolved IRS problem that causes significant hardship, but Form 911 also does not suspend other deadlines by itself.
Official sources
- IRS Publication 3598 — Audit Reconsideration Process
- IRS — Correspondence audit reconsideration
- TAS — Audit reconsiderations