IRS Notice CP3219A
Statutory Notice of Deficiency
IRS Notice CP3219A is a Statutory Notice of Deficiency, also known as a “90-day letter.” It means the IRS plans to assess additional tax based on changes it made to your return and this is your final chance to respond before it becomes final.
If you disagree, you must act quickly. You have 90 days to file a petition with the U.S. Tax Court to challenge the IRS’s determination. After that, the IRS can assess the full amount and begin collection.
▸ Why Did I Get CP3219A?
This notice is often sent when:
The IRS proposed changes in a CP2000 notice and you didn’t respond
Your return omitted income or claimed disallowed deductions or credits
The IRS completed an examination or audit and made adjustments
You did not file a return, so the IRS prepared a substitute return on your behalf
▸ What’s in the CP3219A Notice?
This letter will outline:
The IRS’s proposed changes to your return
The additional tax owed (excluding penalties and interest)
Instructions for how to agree or file a petition with the U.S. Tax Court
A clear deadline — 90 days from the date on the notice (not the day you received it)
▸ After 90 days, you lose your legal right to challenge the changes in Tax Court before paying.
▸ What Should You Do?
Read it carefully. The IRS is making a legal claim that you owe more.
Disagree with the IRS? You must file a petition with the U.S. Tax Court within 90 days.
Agree with the changes? You can sign the enclosed form and pay the amount due.
Never ignore this notice. The IRS will assess the tax and begin collections.
▸ When to Call a Tax Attorney
CP3219A is one of the most serious notices the IRS sends. It is your last opportunity to stop the assessment before the IRS treats the proposed amount as final.
A tax attorney can:
Evaluate the IRS’s claim and determine if it’s accurate
File a Tax Court petition before your 90-day deadline
Gather and submit supporting documentation
Negotiate tax relief options if you agree with the balance but can’t pay
▸ Time Is Limited — Don’t Wait
If you’ve received CP3219A, your clock is already ticking.
Call (903) 595-1000 or fill out this quick form to schedule a consultation.
