The IRS CP3219A notice is a Statutory Notice of Deficiency, also called a 90-day letter. It is the IRS's official proposal to change your tax return based on an audit or examination. This notice is not a bill but a formal notification of the IRS's findings and your right to challenge them in court before any tax is assessed.

Key Features of the CP3219A Notice:

• Formal "Statutory Notice of Deficiency"
• Initiates a strict 90-day deadline to act
• Explains the specific adjustments to income, tax, credits, or deductions
• Details the proposed tax deficiency amount
• Provides instructions on how to petition the U.S. Tax Court
• Your final notice before the tax is legally assessed

You received a CP3219A notice because the IRS has completed a review or audit of your tax return and proposes changes that result in an additional tax liability.

Common Reasons for a CP3219A:

• Audit/Examination Findings: An IRS audit resulted in proposed adjustments.
• Income Discrepancies: Reported income (W-2, 1099, etc.) did not match IRS records.
• Disallowed Deductions or Credits: Claims for deductions, expenses, or tax credits were denied due to lack of substantiation or eligibility.
• Mathematical Errors: Incorrect calculations on the original return.
• Unreported Income: The IRS received information about income you did not report on your return.

Right to Petition the U.S. Tax Court
You have 90 days from the date on the notice (150 days if addressed outside the U.S.) to file a petition with the U.S. Tax Court. This is your right to formally dispute the IRS's findings before you owe the money.

If You AGREE with the Notice:

• You do not need to take any action to petition the court.
• The IRS will assess the tax after the 90-day period expires.
• You will receive a bill (CP22A notice) for the amount due, plus interest and penalties.
• You can then pay the amount in full or arrange a payment plan or settlement.

If You DISAGREE with the Notice:

• You must file a petition with the U.S. Tax Court before the 90-day deadline.
• Filing a petition stops the IRS from assessing the tax or taking collection action until the case is resolved.
• You have the opportunity to present your case and evidence to a judge.

Failing to respond within the 90-day window has serious and final consequences:

Immediate Effects

• The IRS's proposed changes become final by law.
• The tax deficiency is officially assessed to your account.
• You lose the right to dispute the liability in the U.S. Tax Court.

Financial and Legal Impact

• You will receive a bill for the full amount plus accrued penalties and interest.
• The IRS can begin enforced collection actions (wage garnishment, bank levies, tax liens).
• Your refunds for future years can be offset to pay this debt.

Step 1: Review Carefully
Gather your tax records, the original return, and all documentation from the audit or correspondence. Understand exactly what the IRS is changing and why.

Step 2: Seek Professional Help Immediately
This is a complex legal proceeding. A tax professional or attorney can analyze the IRS's position, evaluate your options, and help you build a strong case, whether for settlement or court.

Step 3: Decide Your Course of Action
Based on your professional consultation, decide whether to agree or to petition the Tax Court. If you disagree, your professional will prepare and file the formal petition for you before the deadline.