What Is a CP3219A Notice?
A CP3219A — also called a Statutory Notice of Deficiency, or the "90-day letter" — is one of the most serious notices the IRS sends. It means the IRS has finished proposing changes to your return (usually after an earlier notice like a CP2000 went unanswered) and is now formally notifying you of what it believes you owe.
This is your last step before the IRS can assess the tax without further input from you.
Why You Got One
- An earlier notice, like a CP2000, wasn't responded to within its deadline
- A response was sent but not processed before the IRS's internal deadline
- The IRS completed an examination and is finalizing a proposed increase to your tax
Critical: the 90-day deadline on a CP3219A is firm — 150 days if you're outside the U.S. Unlike many IRS deadlines, this one generally cannot be extended. Missing it means losing your right to challenge the amount in Tax Court before paying.
Your Options
Agree with the changes
Sign and return the enclosed Form 5564 and the matter is resolved.Respond with new information
The IRS can still work with you during the 90-day window even without going to Tax Court. We can prepare the documents; for representation we'll refer you to a qualified representative.Petition U.S. Tax Court
If you disagree, filing a petition within 90 days preserves your right to challenge the deficiency before paying anything. Tax Court petitions are handled by an attorney or an enrolled agent admitted to Tax Court practice — we'll refer you.The Bottom Line
A CP3219A is late-stage — but it's not the end of the road. The key is acting inside the 90-day window, with accurate records and a clear response, before the proposed amount becomes final.
Disclaimer: This page is provided for general educational purposes only and does not constitute tax or legal advice. IRS notice types, deadlines, and procedures described here are based on publicly available IRS guidance and are subject to change. Deadlines mentioned, including any 30-day or 90-day response windows, may not apply to your specific notice — always refer to the dates and instructions printed on your actual IRS notice. Consult a qualified tax professional before taking action. Reading this page does not create a client relationship with FL Tax Experts.