A CP2000 notice from the IRS often raises more than one discrepancy. In many cases, reviewing the notice item by item reveals that the IRS is correct on some points but not on others – in such cases ‘partial agreement’ is an option. 

Partially agreeing with a CP2000 – accepting the changes you confirm are accurate while disputing those you can document as incorrect – is a legitimate and common response position.

Handling a partial agreement correctly matters. An improperly formatted or ambiguous response can result in the IRS treating the entire notice as agreed, or conversely, failing to credit you for the items you did accept. This guide explains exactly how to structure and submit a partial agreement response.

What CP 2000 Partial Agreement Means

A partial agreement means you accept some of the IRS proposed changes but contest others. You are not required to take an all-or-nothing position on a CP2000 notice. The IRS expects and accommodates partial agreement responses through the response form included with the notice.

Partial agreement is appropriate when:

• One item in the notice is undeniably correct (for example, a 1099-INT that you missed) but another item is wrong (for example, 1099-B proceeds being treated as a full gain when you have cost basis documentation)
• The IRS has the right gross figure but applied the wrong tax treatment (for example, treating the full amount of a retirement distribution as taxable when you have basis in the account)
• Multiple discrepancies are listed and some are factually correct while others were caused by payer errors or reporting location differences

The key principle is that your response must be specific: identify which items you agree with and which you do not, and ensure the IRS can clearly see the distinction.

Step 1: Categorize Each Item in the Notice

Before drafting your response, work through each discrepancy listed in the CP2000 and assign it to one of three categories:

• Agree: The IRS figure is correct, this income was not reported, and no exclusion or exception applies
• Disagree: Your return was correct on this item and you have documentation to prove it
• Partially correct: The IRS figure is right, but the proposed tax treatment is wrong, or the amount is correct but an exclusion reduces the taxable portion

For the items in the “agree” column, you will sign off on the proposed changes. For the items in the “disagree” column, you will write an explanation and attach documentation. For “partially correct” items, you will acknowledge the correct portion while documenting the adjustment that reduces the taxable amount.

Step 2: Mark the Response Form Correctly

The response form attached to the CP2000 includes checkboxes for agreement, partial agreement, and disagreement. Check the partial agreement or disagreement box – not the agreement box – when you are contesting any portion of the notice. Checking the agreement box and then writing additional notes explaining why you disagree with certain items creates ambiguity. The form should clearly reflect your overall position.

For the items you do agree with, complete any relevant portions of the calculation section on the response form that ask you to compute the revised additional tax. If the response form includes a table where you can note your figures for each line item, use it.

Sign and date the response form. On a jointly filed return, both spouses must sign. The signature acknowledges that you are responding to the notice and submitting documentation – it is not a blanket agreement to all proposed changes.

Step 3: Write a Clear Explanation for Disputed Items

Your written explanation should address every item in the notice, even items you agree with. For agreed items, you can be brief: “I agree that the 1099-INT income from [Bank] in the amount of $340 was not reported on my return. I accept the proposed change for this item.”

For disputed items, be specific:

• Identify the item by payer name and amount as listed in the notice
• State your position (“This income was reported on Schedule C of my 2022 return as part of gross receipts”)
• Explain why the difference exists (“The 1099-NEC was not mapped by the IRS matching system to Schedule C because it is included within total gross receipts rather than listed separately”)
• Reference your supporting documents (“Please see Exhibit B: Page 2 of my 2022 Schedule C showing gross receipts of $61,200”)

For partially accepted items, explain the portion you accept and the basis for the adjustment:

“I agree that the 1099-R distribution of $18,500 from [Retirement Account] was correctly reported to the IRS. However, I have non-deductible contributions in this account that were tracked on Form 8606. The taxable portion of this distribution is $14,200, not $18,500. The non-taxable portion of $4,300 represents a return of basis. Please see Exhibit C: Form 8606 filed with my 2019 return showing the basis calculation.”

Step 4: Complete the Revised Tax Calculation

One of the most useful things you can do in a partial agreement response is compute the revised proposed tax based only on the items you accept. This tells the IRS examiner precisely what you are acknowledging you owe, independent of the disputed items.

Use the calculation worksheet in the CP2000 response form if one is provided. If not, prepare a simple table in your written response:

• List each item you agree with and the corresponding additional income or adjustment
• Sum the agreed adjustments
• Apply the appropriate tax rate to compute the additional tax on agreed items only
• State the total additional tax you accept

This approach avoids a common processing problem: the IRS treating a partial agreement as a dispute of the entire notice because the total accepted amount was not clearly stated. By quantifying what you accept, you give the examiner a specific figure to process against agreed items while the disputed items continue through review.

Step 5: Gather and Attach Documentation for Disputed Items

Each disputed or partially accepted item requires supporting documentation. Organize your attachments so that each exhibit is clearly labeled and directly corresponds to a specific claim in your written explanation.

For a detailed breakdown of what types of evidence are accepted for different categories of discrepancies, see our guide on 

General principles for documentation:

• Send copies, not originals – the IRS does not return documents
• Include all pages of a document that are relevant, not just the summary page
• If a document is long, highlight or tab the relevant figures – do not expect the examiner to search through a 40-page brokerage statement for one line
• Label every exhibit: “Exhibit A,” “Exhibit B,” and so on, and reference each exhibit by label in your written explanation

Step 6: Submit the Response Package

Compile your response in the following order:

1. Completed response form (checked for partial agreement/disagreement, signed and dated)
2. Your written explanation letter, with item-by-item breakdown
3. Exhibits in the order referenced in your letter

Mail to the address printed on the notice – not a general IRS address. Send by USPS certified mail with return receipt requested, or by a private delivery service that provides a verifiable postmark (FedEx, UPS). Retain the tracking number, a copy of the return receipt, and a complete copy of everything you submitted.

Partial agreement responses are processed in the same pipeline as disagreements. The IRS will review the documentation for disputed items and separately process the accepted items.

What Happens After a Partial Agreement Response

Agreed Items

The items you agreed to will typically be assessed as formal tax charges once your response is processed. You will receive a CP22A or similar assessment notice showing the balance due on the agreed portion. If you included payment for the agreed portion with your response, that payment will be applied. If not, you can pay online or submit Form 9465 for an installment arrangement.

For a full walkthrough of what follows after agreeing with specific changes, see our article on 

Disputed Items

The IRS examiner will review your documentation for the items you disputed. This typically takes 30 to 90 days. Possible outcomes include:

• Full acceptance of your position: the IRS removes the disputed items and sends a closing letter or a revised notice reflecting only the agreed balance
• Partial acceptance: the IRS accepts some of your arguments but not others, and issues a revised notice for the remaining disputed amount
• Rejection: the IRS maintains the disputed items and, if the matter cannot be resolved through correspondence, may issue a Statutory Notice of Deficiency for the remaining proposed amount

Common Errors in Partial Agreement Responses

Checking the Wrong Box

If you check the “agree” box while intending to dispute certain items, the IRS may process the entire response as a full agreement. Always use the partial agreement or disagreement checkbox when contesting any portion of the notice.

Not Computing the Revised Tax

Leaving the calculation section blank or simply writing “see attached” without providing a figure creates unnecessary ambiguity. Complete the calculation for agreed items even if it requires estimating or reconstructing the IRS worksheet.

Leaving Items Unaddressed

If your written explanation does not address a specific item in the notice, the IRS may treat that item as agreed by default. Address every item, even if only to briefly state your agreement.

Submitting Incomplete Documentation

A partial agreement response with strong documentation for one disputed item and no documentation for another leaves the undocumented item in a weak position. Gather and submit documentation for every item you are disputing before sending the response.

Summary

A partial agreement response to a CP2000 is appropriate when the IRS is correct on some items and wrong on others. Check the partial agreement box on the response form, write an item-by-item explanation, quantify the additional tax you accept, attach documentation for every disputed item, and mail the complete package to the address on the notice via certified mail before the 60-day deadline. The IRS will process your agreed items and separately review your disputed items, issuing further correspondence on the outcome of each.