IRS notice guide · Individuals
CP3219A: Statutory Notice of Deficiency
The IRS intends to assess extra tax. You have 90 days to take the case to the U.S. Tax Court.
Urgent: act now
What it means
This notice usually follows a CP2000 that was not answered or not resolved. It is the IRS's formal, legal notice that it plans to assess the extra tax.
It also opens your right to dispute the change in the U.S. Tax Court before you pay. That right has a hard deadline.
How long you have. 90 days from the notice date to file a petition with the U.S. Tax Court. The last day is printed on the notice, and the IRS cannot extend it.
What to do now
- Mark the petition date on your calendar today.
- If you agree, sign and return the consent form, and pay or arrange a payment plan.
- If you disagree and have proof, send it to the IRS right away. It can still resolve the case.
- If the case is not resolved, file a Tax Court petition before the deadline to keep your right to challenge the change without paying first.
Common mistakes
- Assuming the 90 days can be extended. It cannot.
- Sending proof to the IRS and waiting past the petition date for an answer.
Questions
What happens if I do nothing?
After 90 days the IRS assesses the proposed tax and sends a bill, and interest keeps adding up until it is paid.
Do I need a lawyer for Tax Court?
Not always. Small cases can use simpler procedures, and many cases settle with the IRS before trial. We will tell you when an attorney makes sense.
Can Coastal Tax handle this notice for me?
Yes. Paige Fernald is an Enrolled Agent, so with your signed Form 2848 she can speak to the IRS for you, pull your transcripts and answer the notice.
Checked against the agency's own guidance on October 27, 2026: www.irs.gov. This page is general information. Your notice's own dates and instructions come first.