What this letter means
A CP3219A is a Notice of Deficiency. People call it a 90-day letter. A deficiency means the IRS thinks you owe more tax than your return shows.
It usually comes after a CP2000, when the IRS decided your return left out income. The letter isn’t a bill yet. It’s your legal notice that the IRS plans to officially charge the extra tax.
Most of all, it opens a door. You can take the case to the U.S. Tax Court, a court that is separate from the IRS. And you can do that before you pay anything.
How urgent is it?
This is one of the most urgent letters the IRS sends. You have 90 days from the date on the letter to file a petition with the Tax Court. A petition is the form that starts your case. If the letter is addressed to you outside the U.S., you have 150 days.
The letter shows your last day to file. Treat it as absolute. The IRS can’t extend that date. Late petitions are usually dismissed.
You can still send the IRS more proof during this time. But doing that doesn’t stop the clock. If you don’t file by the deadline, the IRS officially charges the tax and sends you a bill.
What we do
We protect the deadline. We make sure your right to petition is protected while we review the case.
We check the amount. Don’t assume the amount is right. We compare the IRS’s numbers to your records and look for what they missed. Sometimes we can settle it with the IRS directly.
We bring in the right help for court. We can’t argue cases in Tax Court. We coordinate with an attorney admitted there, and we do the tax work behind the case. Many cases settle before a trial, but there’s no promise of that.