Statutory Notice of Deficiency
Got an IRS CP3219ANotice? Here's What It Means
Deadline & urgency
The Tax Court petition deadline on a Statutory Notice of Deficiency is strict. Missing it usually means losing the chance to contest the deficiency in Tax Court without paying first.
What this notice means
CP3219A is a Statutory Notice of Deficiency (often called a “90-day letter”). It proposes additional tax and starts a clock: if you don’t petition the Tax Court in time, the IRS can assess the tax without further review in that forum.
This is one of the most legally significant notices taxpayers receive.
Why did I get this?
The IRS completed its examination (or equivalent process) and determined a deficiency for a specific year(s).
You are being given formal notice and the right to go to Tax Court before assessment in qualifying cases.
What should I do next?
Note the petition deadline (typically 90 days from the notice date, 150 days if addressed outside the U.S.—verify on your letter).
If you disagree, strongly consider hiring a tax attorney or other qualified representative to file a Tax Court petition on time.
If you agree, you can sign the enclosed form and pay, or use other resolution paths described in the notice.
Frequently asked questions
Can I talk to the IRS after CP3219A?
Some issues can still be resolved, but the petition deadline still runs. Don’t assume a phone call stops the clock—get professional guidance.
Do I have to go to court?
If you agree with the changes, you may not. If you disagree, Tax Court is often the pre-payment forum if you petition in time.
Is this the same as CP2000?
No. CP2000 is a proposed adjustment under matching rules; a Statutory Notice of Deficiency is a formal step with specific legal deadlines and court rights.