IRS Forms

IRS Form 13825 – Employee Business Expense Questionnaire Guide

Practitioner guide to Form 13825 for 2025 audits: who gets the questionnaire, the four §274(d) substantiation elements, and a copy-paste response packet.

20 min read Updated Jun 14, 2026
Editorial Standards
How we research, review, and update this guide

Every Accountably guide is researched against primary IRS sources, reviewed by a U.S. CPA, and refreshed as guidance evolves. Read our Editorial Guidelines to see how we source, fact-check, and update our content.

Tell us who you are – we will jump to what matters most:

When a client forwards a Form 13825 packet from their examiner, the clock has already been running. The receipts are half in a shoebox and half in an inbox, and the employer reimbursement policy is the one document nobody can find. Form 13825 is the IRS Employee Business Expense Questionnaire, a one-page audit document examiners issue to substantiate unreimbursed employee business expenses, not a return-attached form.

What keeps the deduction in place is not the page itself but the workpaper file behind it. Every response has to reconcile to Form 2106 and satisfy the four substantiation elements under §274(d), which are amount, time, place, and business purpose. Most W-2 employees cannot deduct unreimbursed expenses for tax years 2018 through 2025, with narrow exceptions that still run through Form 2106, so the questionnaire is really about substantiating what was claimed.

Key Takeaways

  • Form 13825 is the IRS Employee Business Expense Questionnaire used during audits to test whether unreimbursed employee expenses are ordinary, necessary, and properly documented.
  • The current publicly available version is Rev. 8-2017, and the IRS forms index still lists it, page last reviewed August 6, 2025. Always confirm the version in your audit notice.
  • Expect to provide specifics for each expense, date, amount, business purpose, and supporting records like receipts, mileage logs, and your employer’s reimbursement policy.
  • Most W‑2 employees cannot deduct unreimbursed expenses for tax years 2018 through 2025, with narrow exceptions that still use Form 2106. The questionnaire is about substantiation for amounts you claimed.
  • Submit your response the way the auditor directs, secure upload where offered, otherwise certified mail, and keep proof of delivery. The IRS has expanded the Document Upload Tool for many notices.

What Form 13825 Is And When You Will See It

Form 13825 is a one‑page questionnaire the IRS uses during examinations to verify unreimbursed employee business expenses. It prompts you to list each expense with the date, amount, and business purpose, and to disclose any reimbursements from your employer. It is short, which can be misleading. The real work sits in your attachments, the receipts, mileage, employer policy, and explanations that tie every line to your W‑2 job.

As of August 6, 2025, the IRS forms index shows Form 13825, Employee Business Expense Questionnaire, with the current PDF labeled Rev. 8‑2017. Auditors often attach their own copy with your notice, so ask your assigned examiner to confirm the version and the exact submission channel they want you to use.

Important backdrop, who can even deduct these expenses now?

Thanks to the Tax Cuts and Jobs Act, the miscellaneous itemized deduction for most unreimbursed employee expenses has been suspended for 2018 through 2025. Only a narrow group, such as Armed Forces reservists, qualified performing artists, fee‑basis government officials, and employees with impairment‑related work expenses, can still claim these costs on Form 2106. If you claimed expenses, the IRS may test them with Form 13825 to see if they truly qualify and are substantiated.

What the auditor is testing

  • Were the expenses ordinary and necessary for your job, and is the business purpose clear?
  • Do your amounts reconcile to your return or to Form 2106 if you used it?
  • Do you have contemporaneous records that match IRS recordkeeping rules for travel, meals, gifts, and vehicles, including mileage details?

How To Get The Right Blank Form, And Why Version Control Matters

You can download the currently posted PDF directly from IRS.gov. Still, best practice is to request the questionnaire from your assigned auditor so you match their preferred format and instructions, especially for upload or mail routing. When you ask, confirm three things in one short email, the tax year, the form revision, and the submission method.

If the notice offers secure digital correspondence, use it. The IRS Document Upload Tool gives you a one‑time link and a unique access code, and you will receive an on‑screen confirmation when your files are received. Save that confirmation in your records.

The What, The How, And The Wow

  • What, Form 13825 documents each unreimbursed employee expense you claimed, plus the evidence behind it.
  • How, follow a five‑step flow, collect, organize, tie each line to proof, send it securely, and keep copies.
  • Wow, go beyond a pile of PDFs. Use a simple index and a one‑page summary that lets the reviewer follow your trail without hunting. That small touch often shortens review time.

Pro tip, think like a reviewer. If someone new opened your packet, could they find the mileage for March 12, the client visit you described, and the employer policy showing no reimbursement, in under one minute?

Step‑By‑Step, Completing Form 13825 For An Audit

Start by matching names, address, and SSN to your filed return. Confirm the tax year under examination. Then itemize expenses line by line. Use the table below as your checklist.

Step Action What “good” looks like
1 Obtain the current questionnaire Rev. 8‑2017 PDF or the copy attached to your notice, confirmed by your auditor.
2 Complete identity and tax year Exactly as shown on your filed return, including middle initials if used.
3 Itemize expenses accurately Date, vendor, amount, business purpose, tie‑outs to Form 2106 if used.
4 Attach documentation Receipts, mileage logs, agendas, employer reimbursement policy or email.
5 Review and submit on time Secure upload with confirmation, or certified mail with tracking.

How to write a clean business purpose

  • Weak, “Client meeting.”
  • Strong, “3/12, 46.2 business miles round‑trip to Acme Co., quarterly service review tied to Contract 2025‑Q1.”

The second one answers who, what, when, where, and why. It also makes it easy to match to a calendar invite or agenda.

Vehicle expenses and mileage logs

If you claimed vehicle costs, your log should show date, destination, miles, and purpose. Keep totals for the year, business versus personal (commuting between home and a regular workplace is a personal expense and is never deductible, so exclude those miles from your business totals). Publication 463 explains what elements must be in your records and what “adequate records” mean, including sampling rules if your log is representative.

Employer reimbursement policy

Many audits turn on this one document. Include the written policy or an email from HR confirming whether you were eligible for reimbursement and whether you used an accountable plan. If you were reimbursed, show the amount and how you handled it on your return (an expense you could have submitted under your employer's plan but chose not to is generally not deductible, so document why anything claimed outside the plan was not eligible for reimbursement). Publication 463 covers employer reimbursements and accountable plans at a practical level.

Supporting Documents And A Simple Index That Auditors Love

Your packet should make it easy to verify every number on Form 13825. Use this three‑part structure.

  • Cover letter, one page, listing the total categories and a short explanation of any unusual items.
  • Index, one page, that maps, for example, “Mileage, March,” to “Tab B, Pages 1–4.”
  • Tabs or clearly named PDFs, one tab per category, receipts first, logs next, policy last.

Aim for clarity, not volume. Ten clean pages beat thirty scattered screenshots.

Recordkeeping that holds up

  • Keep original receipts where possible, clean scans are fine for submission.
  • Maintain contemporaneous mileage and trip notes (records reconstructed at year-end carry significantly less weight than entries captured at or near the time of each trip, so if reconstruction is unavoidable, anchor it to calendar entries, client emails, or fuel receipts and disclose that the log was reconstructed).
  • Save employer policy, card statements, and calendar entries that tie to the purpose (card statements alone establish amount and date but not business purpose, so pair them with itemized receipts and contemporaneous notes to satisfy IRC §274(d)).
  • Follow IRS retention guidance, generally 3 years, 6 years if income is substantially understated, and 7 years for bad debt or worthless securities. Keep employment tax records at least 4 years (and if a return is fraudulent or was never filed, there is no statute of limitations on assessment, so keep those records indefinitely).

Quality Control, A Five‑Minute Self‑Audit Before You Send

  • Do totals on Form 13825 match your return or Form 2106 where used?
  • Does every line have a document, receipt, or log entry?
  • Is your business purpose plain English, no jargon?
  • Did you include the employer policy or HR email about reimbursements?
  • Do you have proof of submission, upload confirmation, or USPS tracking ready?

Keep a complete copy of everything you send. If you mailed it, photograph the certified mail receipt next to the addressed envelope for your records.

Submission Options And How To Communicate With The Auditor

Pin down logistics early. Ask your auditor for the preferred channel, secure upload using the IRS Document Upload Tool, encrypted email if offered, or a mailing address. When the IRS provides a unique upload link and access code, you can submit up to dozens of files and you will receive a confirmation message when the upload is complete. Save that confirmation.

If you mail, use certified mail with tracking and keep a copy of the entire packet (regular first-class USPS leaves no proof of timely delivery and is a frequent source of preventable assessment errors). Respond by the deadline on your notice. If you need more time, request an extension in writing before the due date on the letter. The IRS generally communicates first by mail and lists a due date and contact details on the notice.

Smart Safeguards Against Common Audit Mistakes

  • Confirm you are using the same revision of Form 13825 the auditor expects, currently Rev. 8‑2017 on IRS.gov.
  • Do not send originals unless instructed. Keep originals, send copies.
  • Redact unrelated personal data on statements when appropriate.
  • Use clear file names, for example, “B‑Mileage‑March‑Acme‑46.2mi.pdf.”
  • Keep all auditor communications in writing where possible, even after a phone call, send a short recap email.

Closing Advice

Form 13825 asks you to prove what you claimed, nothing more, nothing less. Get the right revision, confirm how the auditor wants it delivered, document the story behind every dollar, then send a tight, readable packet with delivery proof. If your expenses are legitimate and your records are clean, this is a chore, not a crisis. For the next year, improve your logs and your reimbursement process so you spend less time chasing receipts and more time doing your real job. Publication 463 has the road map for better records, use it.

This article is for general information. For specific advice, consult your tax professional and the instructions on your IRS notice. If any rule changed after November 8, 2025, follow the most current IRS guidance on IRS.gov.

Common Mistakes We See Every Season

Most Form 13825 disallowances trace back to a small set of recurring traps, and they tend to be substantiation gaps rather than questions of whether the underlying expense was real. Here is what my team sees every audit cycle.

1. Treating Form 13825 as a return-attached form. Some respondents try to "amend" or "refile" Form 13825 as if it were a schedule that goes with Form 1040. It is an examination questionnaire delivered by an auditor, not a self-filed form, and treating it that way wastes the response window and confuses the examiner. Fix: Complete and return Form 13825 only when the examiner requests it, through the channel listed on the notice. Route any return corrections through Form 1040-X separately.
2. Including daily commute mileage in vehicle totals. The most common vehicle disallowance is travel between home and a regular workplace recorded as business miles. Per IRS Publication 463, home-to-regular-workplace travel is a personal expense and never deductible. Fix: Separate commute miles from business miles before any total runs, and apply the 2025 standard business mileage rate of 70 cents per mile only to deductible legs, per IRS Notice 2025-5.
3. Submitting a reconstructed log as if it were contemporaneous. A spreadsheet built in March from calendar guesses does not carry the same weight as entries captured at or near the time of each trip. Under IRC §274(d), reconstructed records carry significantly less weight than contemporaneous ones. Fix: If reconstruction is unavoidable, anchor every line to corroborating evidence (calendar entries, client emails, fuel receipts) and disclose in the cover letter that the log was reconstructed.
4. Offering credit-card statements as substitutes for receipts. A statement shows amount and date, not business purpose or attendees, so on its own it fails the §274(d) four-element test (amount, time, place, business purpose). This is a recurring meal and travel disallowance pattern. Fix: Pair every statement line with the itemized receipt, the business purpose, and (for meals or gifts) the business relationship. Apply the 50% meal deduction limit on the qualifying total.
5. Deducting expenses the employer would have reimbursed. If an accountable plan was available and the taxpayer chose not to submit the expense, it is generally disallowed. The questionnaire asks specifically about reimbursement, and the answer drives the result. Fix: Pull the written employer reimbursement policy upfront and document, in writing, why anything claimed outside the plan was not eligible (scope, deadline, or category exclusion).
6. Mailing the response by regular first-class USPS. Regular first-class mail leaves no proof of timely delivery, and a missed deadline can turn a defensible response into an automatic assessment. Fix: Use the IRS Document Upload Tool when the notice offers it, or send by certified mail with tracking. Retain the upload confirmation or USPS receipt with the workpaper file.

Reusable Checklists

These checklists are copy-paste ready for a firm SOP folder. Each one walks the §274(d) four-element substantiation test (amount, time, place, business purpose) in the order an examiner reviews the packet.

§62(a)(2) eligibility scan

  • Confirm the tax year under examination falls within the §67(g) suspension window for most W-2 employees (2018 through 2025).
  • Identify which of the four surviving §62(a)(2) categories applies: Armed Forces reservist traveling more than 100 miles from home, qualified performing artist, fee-basis state or local government official, or employee with impairment-related work expenses.
  • Pull the supporting evidence for that category (reservist orders, performing-artist income test, fee-basis appointment letter, or impairment-related expense documentation).
  • If none of the four categories applies, document why no deduction should have been claimed and prepare the disallowance position before the examiner does.
  • Confirm whether Schedule A or Form 2106 was used on the filed return for the year under audit, and pull the original return.

§274(d) substantiation packet

  • Build a line-by-line reconciliation grid tying every Form 13825 entry back to the amount the taxpayer actually deducted on Form 2106, since unreconciled differences are routinely disallowed.
  • Tag each travel, meal, gift, or vehicle line with the four §274(d) elements: amount, time, place, and business purpose.
  • Collect contemporaneous mileage logs (date, destination, business miles, business purpose) and exclude any home-to-regular-workplace miles before totals run.
  • Pull the written employer reimbursement policy and any accountable-plan documentation, and flag any expense that could have been reimbursed but was not claimed.
  • Apply the 50% meal deduction limit and the 2025 standard mileage rate of 70 cents per business mile, per IRS Notice 2025-5.
  • Index the packet: cover letter, reconciliation grid, then one tab per category with receipts, logs, and policy in that order.
  • Cross-reference IRS Publication 463 for any travel, gift, or vehicle line that involves a judgment call.

Delivery and audit close

  • Confirm the submission channel with the examiner: IRS Document Upload Tool (preferred) or certified mail with tracking.
  • Submit before the deadline shown on the notice; request a written extension only before the due date if the packet is not ready.
  • Save the upload confirmation message or the USPS certified-mail receipt with the workpaper file.
  • Retain the response packet for the longer of the applicable retention period: 3 years default, 4 years for employment tax records, 6 years if gross income was understated by more than 25%, 7 years for bad-debt or worthless-securities claims, and indefinitely if the return was fraudulent or never filed.
  • Calendar the examiner follow-up date and a 60-day internal status check on the workpaper file.

Keep 13825 Season From Stalling

Form 13825 questionnaires arrive with a hard examiner deadline, and the work is rarely as clean as pulling the file and writing a cover letter. For the 2018 through 2025 audit cycle, IRC §67(g) suspended the Schedule A deduction for most W-2 employees, so a defensible response first has to establish whether the taxpayer fits one of the four §62(a)(2) categories: Armed Forces reservist traveling more than 100 miles from home, qualified performing artist, fee-basis state or local government official, or employee with impairment-related work expenses. The §274(d) substantiation test then requires four elements – amount, time, place, and business purpose – for every travel, meal, gift, or vehicle line item, per Internal Revenue Code §274(d).

The fix is to treat each Form 13825 like a mini-engagement with its own workpaper file, a reconciliation grid back to Form 2106, and a reviewer pass before anything reaches the examiner. Reconstructed logs and credit-card statements alone do not survive a §274(d) review; only contemporaneous records, or sufficient corroborating evidence anchored to calendar entries and supporting documents, do, per IRS Publication 463.

  • Build a line-by-line reconciliation grid tying every Form 13825 entry to the Form 2106 (or Schedule A) amount the taxpayer actually deducted, since unreconciled differences are routinely disallowed.
  • Pull the employer reimbursement policy and any accountable-plan documentation upfront, because any expense that could have been reimbursed under an employer plan and was not is generally disallowed.
  • Separate commuting miles from business miles before totals run, and apply the 2025 business standard mileage rate of 70 cents per mile, per IRS Notice 2025-5.
  • Pair every meal entry with an itemized receipt, the business purpose, and the attendees at the 50% deductible limit; statements alone fail the §274(d) test.
  • Submit the response through the IRS Document Upload Tool or by certified mail with tracking by the notice deadline, since regular first-class mail leaves no proof of timely delivery.

That is the kind of structured response we build at Accountably, with SOP-driven workpapers, a preparer-to-reviewer pass, and turnaround SLAs that fit the examiner's clock.

FAQs

Is Form 13825 filed with my tax return?

No. Form 13825 is the IRS Employee Business Expense Questionnaire, a one‑page audit document an examiner issues during an examination, not a return‑attached schedule. Complete and return it only when the examiner requests it, through the channel listed on your notice. Route any actual return corrections through Form 1040-X separately.

Which version of Form 13825 should I use?

The current publicly posted PDF is Rev. 8‑2017, and the IRS forms index still lists it. Auditors often attach their own copy with your notice, so confirm the tax year, the form revision, and the submission method with your assigned examiner in one short email before you respond.

Can W‑2 employees still deduct these expenses?

For most W‑2 employees the miscellaneous itemized deduction is suspended for tax years 2018 through 2025. Only narrow groups, such as Armed Forces reservists, qualified performing artists, fee‑basis government officials, and employees with impairment‑related work expenses, can still claim these costs on Form 2106. The questionnaire tests whether what you claimed truly qualifies and is substantiated under §274(d).

How should I submit my Form 13825 response?

Submit the way the examiner directs. Use the IRS Document Upload Tool when the notice offers it, which gives you a one‑time link and access code and an on‑screen confirmation. Otherwise use certified mail with tracking. Respond by the deadline on your notice and keep proof of delivery with your workpaper file.

Every Form Represents Work Your Team Has to Deliver

Accountably embeds trained offshore teams into your workflow – so more returns get handled without more burnout.

30-Day Guarantee 20+ Firms Served SOC 2 Aligned