IRS CP22E
Examination Results — Balance Due
The IRS audited your return and says you owe additional tax.
Deadline
30 days to appeal; 60 days to pay before enforcement
You have 30 days to request reconsideration or file a Tax Court petition. After 90 days (if you received a 90-day letter), the assessment becomes final.
Respond promptly to protect your options and avoid escalation.
What IRS CP22E Means
CP22E is issued after an IRS audit (examination) to confirm that the examination is complete and a balance is due based on the audit results. If you agreed to the audit findings (or did not respond), the IRS has now assessed the additional tax.
This notice is distinct from audit notices like Letter 525 or Letter 531 — those are proposals. CP22E means the assessment has been formally made. The balance shown represents the additional tax the IRS determined you owed, plus any penalties and interest accrued.
Receiving CP22E does not necessarily mean the audit results were correct. You may still have options to dispute the assessment, including requesting audit reconsideration, filing a petition in Tax Court (if within the applicable window), or pursuing the IRS Office of Appeals.
What the IRS Can Do If You Don't Respond
- Formally assess the balance and begin the collection process
- Accrue failure-to-pay penalties and daily interest on the unpaid amount
- Issue subsequent balance-due notices leading to levy action
- File a Notice of Federal Tax Lien against your property
- Assign your case to a Revenue Officer for accelerated collection
What You Should Do Right Now
- 1
Determine whether you agreed to the audit findings or whether this notice is the first you're hearing of the results
- 2
If you disagree, assess whether you are within the window to petition Tax Court or request audit reconsideration
- 3
Gather all audit correspondence, your original return, and supporting documentation
- 4
Contact a CPA or tax attorney immediately — audit reconsideration and Tax Court have strict deadlines
- 5
If you agree with the balance, arrange payment or a payment plan to stop penalty accrual
Resolution Options Available to You
Challenge the audit results through audit reconsideration if you have new evidence
Dispute the assessment through the IRS Office of Appeals
Petition U.S. Tax Court if you are within the applicable deadline
Set up payments while your dispute is pending
Request removal of audit-related penalties
Frequently Asked Questions About IRS CP22E
Can I still appeal after receiving CP22E?
It depends on where you are in the process. If you previously received a 90-day letter (Notice of Deficiency) and the Tax Court petition window has closed, the assessment is final and collection remedies are limited. Audit reconsideration may still be available with new information.
What is audit reconsideration?
Audit reconsideration is an IRS process that allows you to request a re-examination of your case if you have new documentation or believe the original audit was incorrect. It does not suspend collection, but it can result in a reduced assessment.
Does CP22E mean I'm being criminally investigated?
No. CP22E is a civil assessment notice from a standard examination. Criminal investigations are handled separately by IRS Criminal Investigation (CI) and involve very different processes.
How do I know if I'm still in the Tax Court window?
If you received a Notice of Deficiency (Letter 3219), you had 90 days to file a Tax Court petition. Check the date on that letter. If you never received a Notice of Deficiency before CP22E, consult a tax professional about reconsideration options.
Professional References
IRC: IRC §6213 — Jurisdiction of Tax Court; IRC §6214 — Determinations by Tax Court; IRC §6651 — Penalties
IRM: IRM 4.13.1 — Audit Reconsideration Procedures
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