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IRS letters › CP3219A

Notice CP3219A

Notice of deficiency (the "90-day letter")

The IRS has decided you owe more tax. If you disagree, your only way to dispute it before paying is a petition to the US Tax Court, filed within 90 days.

Also called: Letter 3219

Very urgent
Deadline90 days from the notice date (150 days if it's addressed to you outside the US). The deadline can't be extended.

What it means

This is the legal notice that the IRS will assess the extra tax. It usually follows a CP2000 or an audit you didn't resolve. It gives you the right to have the US Tax Court decide the dispute without paying first. The last day to petition is printed on the notice.

What to do

  1. If you agree, sign the waiver form that came with it and pay, or set up a payment plan.
  2. If you disagree, file a petition with the US Tax Court by the last day shown. You can do it online on the Tax Court's website. The filing fee is $60 and can be waived. The small-case procedure is simpler for disputes of $50,000 or less per year.
  3. You can still send the IRS your documents, but that doesn't stop the 90-day clock. Only a timely petition protects your right to go to court.

Don't

  • Don't miss the date. After it passes, the IRS assesses the tax, and you can only challenge it by paying first and claiming a refund.

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Is it really from the IRS?

The IRS starts contact by mail. A real notice has a notice number and your tax year, and you can see it, with any balance, in your IRS online account. The IRS never demands payment by gift card, crypto or wire transfer, and never threatens arrest. If in doubt, call the IRS using a number from IRS.gov, not one from the letter.

The law behind it

§ 6212 § 6213 § 7463

Free help

The Taxpayer Advocate Service is an independent part of the IRS that helps when a problem isn't being resolved (Form 911, or 877-777-4778). Low Income Taxpayer Clinics represent people for free or a small fee, many in Spanish and other languages.

Other letters

LT11Final notice: intent to levy and your right to a hearingVery urgentCP11The IRS corrected your return, and you oweCheck itCP12The IRS corrected your return, and your refund changedGood to know

All IRS letters

General information, not tax or legal advice. Always follow the dates and instructions printed on your own notice.