A partial agreement response to a CP2000 is one of the most common and also most nuanced response types. It requires you to clearly separate the items you accept from those you dispute, communicate a revised tax figure that reflects only the agreed portion, and provide full documentation for everything you are contesting.

A partial agreement response that does not clearly delineate these components is often processed incorrectly – either as a full agreement or as a bare disagreement without the benefits of the agreed portion being credited.

This article is part of our letters and templates hub and explains the common partial agreement scenarios, provides a sample letter, and covers the filing process for submitting this type of response.

Common Partial Agreement Scenarios

• A CP2000 lists three discrepancies; one is correct and two are the result of income already reported on your return in a different location
• A 1099-B shows gross proceeds correctly, but the IRS is treating the full amount as taxable gain because no cost basis was reported; you agree on the proceeds but dispute the gain amount
• A 1099-R shows a distribution that is partially taxable and partially a return of non-deductible contributions tracked on Form 8606
• Multiple 1099-NEC forms are listed; some represent income you genuinely omitted, and others represent income included in your Schedule C gross receipts

In each case, the correct response accepts the accurate items and disputes the rest – not through a general disagreement, but through specific item-by-item treatment.

Sample Partial Agreement Letter

[Your Full Name]

[Your Address]

[City, State, ZIP]

[Your Social Security Number]

[Date]

Internal Revenue Service

AUR Unit

[IRS Address from Notice]

Re: CP2000 Notice – Tax Year [XXXX] – Notice Number [XXXXXXXXXX]

To Whom It May Concern:

I am writing in response to CP2000 Notice dated [Notice Date] for the tax year ending

December 31, [XXXX]. I agree with some of the proposed changes and disagree with

others, as detailed below.

ITEM 1: 1099-INT from [Bank Name] – $[Amount] – AGREE

I agree that the interest income of $[Amount] reported by [Bank Name] was not included

on my original return. I accept the proposed adjustment for this item in full.

ITEM 2: 1099-NEC from [Client Name] – $[Amount] – DISAGREE

I disagree that this income was unreported. The $[Amount] received from [Client Name]

is included within the gross receipts total of $[Total] reported on Schedule C,

Line 1 of my return. The income was fully reported and is subject to self-employment

tax as shown on my Schedule SE.

Please see Exhibit A: Schedule C from my [XXXX] Form 1040 showing gross receipts

of $[Total] on Line 1.

Please see Exhibit B: Form 1099-NEC from [Client Name] confirming the $[Amount].

ITEM 3: 1099-B from [Brokerage Name] – Gross Proceeds $[Proceeds] – PARTIAL AGREEMENT

I agree that the sale of [Security Name] produced gross proceeds of $[Proceeds] as

reported on Form 1099-B. However, I disagree with the proposed treatment of the full

proceeds as a taxable gain. My cost basis for the shares sold was $[Basis], resulting

in a taxable long-term capital gain of $[Gain], not $[Proceeds].

Please see Exhibit C: Form 1099-B from [Brokerage] showing gross proceeds of $[Proceeds].

Please see Exhibit D: Purchase confirmation dated [Date] showing purchase price of

$[Basis] for [Number] shares.

REVISED PROPOSED TAX CALCULATION

Based on the above, I accept the proposed adjustment for Item 1 ($[Amount] in

additional interest income), which I understand will increase my taxable income by

$[Amount] and result in an estimated additional tax of $[Tax Amount] at my

applicable rate. I disagree with the proposed adjustments for Items 2 and 3 for

the reasons stated above.

I request that the IRS process the agreed portion of this response and remove the

proposed adjustments for Items 2 and 3 pending review of the attached documentation.

I can be reached at [Phone Number] if additional information is needed.

Sincerely,

[Your Signature]           [Date]

[Your Printed Name]

[Spouse’s Signature]        [Date] (if joint return)

[Spouse’s Printed Name]

How to Split Agreement and Disagreement Correctly

The critical discipline in a partial agreement letter is precision. Every item in the notice must be addressed. For each one, your position must be clearly stated as agree, disagree, or partial. Do not use ambiguous language such as “this item may be partially correct” without following up with specific figures showing what portion you accept.

For the response form that accompanies the letter: check the partial agreement or disagreement checkbox (not the full agreement checkbox), and complete the calculation section showing the revised proposed tax you accept based only on the agreed items. This gives the IRS examiner a specific number to process against the agreed items while the disputed ones proceed through review.

Supporting Evidence for Disputed Items

For every item you are disputing in a partial agreement response, the same documentation requirements apply as in a full disagreement response. Each disputed position requires a specific factual claim and a labeled exhibit that supports it.

For a complete breakdown of what documents to attach for each type of dispute, see our guide on the CP2000 response letter process. For Form 5564 completion instructions that accompany this letter, see our guide on Form 5564 instructions.

Filing the Partial Agreement Response

Assemble your package in the following order: the signed response form (with the disagreement or partial agreement box checked), your partial agreement letter, and exhibits labeled in the order they are first referenced. Make a complete copy before mailing. Send via USPS certified mail with return receipt requested to the address on the notice.

Summary

A partial agreement CP2000 response accepts specific items the IRS is correct about while disputing others with documentation. The letter must clearly label each item’s treatment (agree, disagree, or partial), compute and state the revised proposed tax for agreed items, and attach exhibits for every disputed position. Use the sample above as a template, adapt it to your notice details, and complete the response form to reflect the partial position before submitting.