Letter 3219

A Letter 3219 is a statutory notice of deficiency issued after a mail audit (Letter 531 is the in-person twin; CP3219A is the closely related notice from income-matching cases). It is the taxpayer's legal notice of a proposed deficiency — and the ticket to challenging it in the U.S. Tax Court before paying.

“The examination is over and we propose this deficiency. Agree by signing the enclosed waiver, or petition the United States Tax Court within 90 days of the date on this notice — 150 days if you're abroad. We're required to send this by certified mail to your last known address, and we cannot shorten or lengthen the 90 days.”

Fixed by statute — no one at the IRS can extend it, and the Tax Court dismisses late petitions. Responding to the IRS with new information during the window is worthwhile and often resolves the case, but it never pauses the clock. If the last day falls on a weekend or D.C. holiday, the next business day counts; electronic filing is accepted until 11:59 p.m. Eastern.

• The notice, with the petition deadline printed on it
• The audit report and every prior letter in the case
• Documentation for the disputed items
• Proof of your current address if the notice went somewhere old — it matters legally

• Filing the protective Tax Court petition while settlement talks continue
• Assembling the record that changes the IRS's position inside the window
• Appeals conferences after the petition — most petitioned cases settle without trial
• Audit reconsideration as the fallback when the window is already gone