IRS & TAXES

What is an IRS CP3219A notice (Statutory Notice of Deficiency)?

SHORT ANSWER

A CP3219A is a Statutory Notice of Deficiency — the IRS’s formal proposed tax increase, usually after an unresolved CP2000. It gives you 90 days (150 if the notice is addressed outside the U.S.) to petition the U.S. Tax Court to dispute the tax without paying it first, under Internal Revenue Code § 6213(a). The 90-day deadline cannot be extended.

A CP3219A notice — a “Statutory Notice of Deficiency,” often called a 90-day letter — is the IRS’s formal notice that it intends to increase your tax, typically after a CP2000 income mismatch you didn’t resolve. It is a legally significant document: it opens your one guaranteed window to challenge the tax in U.S. Tax Court BEFORE paying, and that right is fixed by Internal Revenue Code § 6213(a). You have 90 days from the notice date (150 days if it is addressed to you outside the United States) to file a Tax Court petition. That deadline is jurisdictional — the court cannot extend it, and neither can the IRS. Within the window you can also just agree and sign the enclosed Form 5564, or send the IRS documents showing the proposed change is wrong. But if you do nothing, when the 90 days expire the IRS assesses the tax and your options narrow to paying and suing for a refund. Because the deadline is unforgiving, a CP3219A is the notice most worth acting on immediately.

What to do, in order

Find the deadline date on the notice — you have 90 days (150 if addressed outside the U.S.) and it cannot be extended.
Decide: agree (sign and return Form 5564), or dispute.
To dispute without paying first, file a petition with the U.S. Tax Court on or before the deadline (IRC § 6213(a)).
If you have documents proving the change is wrong, send them to the IRS address on the notice — but do NOT let that replace the Tax Court deadline.
If the numbers are large or the issue is complex, get a tax professional or Low Income Taxpayer Clinic involved before day 90, not after.

Common questions

How long do I have to respond to a CP3219A?

90 days from the date on the notice (150 days if it is addressed to you outside the United States) to petition the U.S. Tax Court. Internal Revenue Code § 6213(a) sets this deadline and it cannot be extended.

What happens if I ignore a CP3219A?

When the 90-day window closes the IRS assesses the proposed tax and can begin collection. You then lose the right to contest it in Tax Court without first paying and suing for a refund.

Is a CP3219A the same as a CP2000?

No. A CP2000 is a proposal you can still work out informally. A CP3219A is the formal deficiency notice that starts the 90-day Tax Court clock — it is the escalation of an unresolved CP2000.

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This is general information, not legal, tax, or financial advice, and it doesn’t create a professional relationship. Rules have exceptions and change over time. For advice on your specific situation, consult a licensed professional.