Reaudit

1. Provided the statute of limitations remains open, the tax commissioner may reaudit years that were previously audited. Such reaudit is limited to issues and facts not previously audited. Documents previously supplied by the taxpayer may not be requested in future audits of the same year unless the taxpayer utilizes those documents as relevant to the new audit or the tax commissioner and taxpayer have otherwise agreed. 2. The tax commissioner may not audit tax years previously audited if the purpose of the reaudit is to examine issues which were assessed and subsequently resolved in the previous audit.