All notices › Income Discrepancy
IRS CP3219A: Statutory Notice of Deficiency (90-Day Letter)
Straight answer: A CP3219A is the Statutory Notice of Deficiency — the IRS's formal determination that you owe additional tax (usually following an unanswered CP2000). It is your ticket to Tax Court, and the clock is absolute.
How many days do I have to respond to a CP3219A?
90 days from the date printed on the notice (not the day you opened it). 90 days from the notice date (150 if outside the U.S.) to file a Tax Court petition. This deadline CANNOT be extended — miss it and the tax is assessed, leaving only pay-then-sue or audit reconsideration.
Your response deadline is approximately — days from today.
What should I do right now?
- Decide fast: agree (sign and arrange payment), get the IRS to correct it informally (possible but the 90-day clock keeps running), or petition Tax Court.
- Petitioning Tax Court costs $60 and does NOT require a lawyer — small cases (under $50,000/year) use simplified procedures, and most petitions settle with IRS counsel before trial.
- Do not assume silence fixes anything — after day 90 the proposed amount becomes a real, collectible assessment.
The costly mistake people make with a CP3219A
Trying to 'work it out' by mail and letting day 90 pass. The petition preserves every negotiation option; missing it forfeits the strongest one.
Do I need professional help with a CP3219A?
Yes for anything sizable. Even a one-hour consult before the deadline can preserve rights worth thousands.
Want a professional to look at your CP3219A?
Tell us what you received and we'll connect you with a licensed tax resolution professional for a free case review. No obligation.
Get my free case review →