IRS Notice Decoder
Notice CP3219A: Statutory Notice of Deficiency
CP3219A sets a firm deadline. It is not a bill or an audit, but the Tax Court date can't be extended.
What CP3219A means
- The IRS found your income tax needs to be adjusted, based on information from others such as your employer or bank.
- It isn't a bill or an audit. It notifies you of a proposed change in your tax.
- It explains how the amount was calculated, what to do if you agree or disagree, and how to challenge the decision in U.S. Tax Court.
Deadline calculator
The IRS describes a 90-day response period and says to file any Tax Court petition by the date listed on the notice. The Tax Court can't consider a late petition, and the IRS can't extend the time. Always use the date printed on your notice. This estimate is only a check.
Federal law (26 U.S.C. §6213(a)) sets the Tax Court petition window at 90 days after the notice of deficiency is mailed, or 150 days if the notice is addressed to a person outside the United States. If the last day falls on a Saturday, Sunday, or legal holiday in the District of Columbia, it isn't counted as the last day.
This is an estimate counted from the printed date. If the count ends on a weekend, the calculator moves it to Monday. It doesn't adjust for D.C. legal holidays. Always go by the dates and instructions on your own notice.
Source: IRS CP3219A page; 26 U.S.C. §6213(a)If it is ignored, and what usually comes next
If you don't act, the IRS says:
- If the IRS doesn't hear from you and you don't file a petition, it will assess the proposed changes and send you a bill.
- Interest builds on the unpaid balance until it is paid in full.
What you can do yourself
- If you agree, follow the notice instructions and reply with the enclosed Form 5564.
- If you disagree, reply right away with a signed statement and supporting documents. The IRS works with you during the 90-day period, and can generally accept information by phone.
- If a third party reported wrong information, ask them for a corrected document, and tell the IRS you're waiting on it.
- To challenge the change in Tax Court, file a petition by the date on the notice.
- If you have other items to report, file Form 1040-X marked "CP3219A" with Form 5564.
- Reply by upload (fastest), fax, or mail. Pay any tax due, or apply for a payment plan or Offer in Compromise.
When to bring in an Enrolled Agent
The IRS notes that you can authorize someone to represent you or contact it for you. Consider getting help if:
- You disagree and the 90-day clock is running.
- You're considering a Tax Court petition.
- The adjustment involves several income sources or years.
Official IRS resource
Read the IRS's own explanation: IRS, Understanding your CP3219A notice (irs.gov).
This page is general information, not tax or legal advice. It doesn't create a client relationship. Advice for your situation starts only after a formal engagement with Tristan D. Taylor, EA. Always follow the instructions on your own notice.