IRS CP3219A Notice: Statutory Notice of Deficiency (90-Day Letter)
A CP3219A is the Statutory Notice of Deficiency — the IRS's formal determination that you owe additional tax, giving you exactly 90 days to petition the U.S. Tax Court before the tax is assessed.
Deadline calculator
The CP3219A clock runs from the date printed on the notice — not the day you opened it.
Estimate only, based on the standard 90-day CP3219A window. Your notice controls — always use the specific date printed on it.
What a CP3219A actually means
This usually follows an unanswered CP2000 or audit. It's the legal turning point: after 90 days, the proposed tax becomes a real assessed debt and collection begins.
Petitioning Tax Court sounds drastic but is often just leverage — most petitions settle with IRS counsel or appeals without a trial, and filing preserves your right to dispute without paying first. Alternatively, you can still submit documentation to the IRS during the window and ask them to reverse the deficiency.
What to do, step by step
- 1Calendar the 90-day deadline (it's printed on the notice) — no extensions exist.
- 2If the IRS is simply wrong, immediately send documentation to the address on the notice and ask for a corrected (rescinded) notice — but don't let this run out your clock.
- 3To preserve all rights, file a Tax Court petition before day 90 (the filing fee is modest and cases usually settle).
- 4If the deficiency is correct, you can sign the waiver (Form 5564) to limit interest accrual and arrange payment.
- 5Get professional help — this letter has the most rigid deadline in tax procedure.
Common questions
Can I still fix things after a 90-day letter without going to court?+
Yes — the IRS can rescind or correct a Notice of Deficiency if you provide convincing documentation during the window. But documentation alone doesn't stop the 90-day clock; only a Tax Court petition preserves your pre-payment appeal rights.
What happens after 90 days if I do nothing?+
The tax is assessed, bills begin (CP14), and the collection sequence follows. Your only remaining dispute path is paying first and suing for refund, or audit reconsideration — both harder than acting in the window.
Received a CP3219A? Get it handled.
Talk to a tax specialist about your notice — free, no pressure, no judgment.