CP3219A

A CP3219A is a statutory notice of deficiency — the formal proposal of a tax change, usually following an unresolved mismatch. The IRS's own page says it plainly: it isn't a bill and isn't an audit. What it is, uniquely, is a ticket: it opens a 90-day window to challenge the change in U.S. Tax Court before paying anything.

“We propose to adjust your tax based on information from employers, banks, and others. If you agree, sign the enclosed waiver. If you disagree, work with us during the 90-day period — and know that you have the right to petition the U.S. Tax Court by the date on this notice. That court date cannot be extended by anyone.”

This is one of the few genuinely rigid deadlines in tax practice — the IRS itself cannot extend it, and the Tax Court cannot hear a late petition. Working with the IRS during the window is encouraged and often resolves the issue, but it never pauses the 90 days. The date is printed on the notice; it deserves a calendar entry the day the letter is opened.

• The complete notice, including Form 5564 (the waiver) and the printed petition deadline
• Your return for the year and every earlier notice about this issue
• Documentation for each disputed item
• Corrected third-party forms, or requests for them, if the payer's reporting was wrong

• Triaging quickly: resolve with the IRS inside the window, petition Tax Court, or both in parallel
• Preparing the Tax Court petition when protecting the deadline is the wise move
• Negotiating with the IRS during the 90 days so court is rarely needed
• Making sure nothing is signed away that shouldn't be