CP3219A Notice — Statutory Notice of Deficiency and Tax Court Rights

Direct answer

CP3219A is a Statutory Notice of Deficiency. It means the IRS is proposing to assess additional tax and you generally have 90 days to petition the US Tax Court if you disagree — a critical legal deadline.

CP3219A usually follows an unanswered or unresolved CP2000. This is not a collection levy notice — it is an exam/deficiency notice with formal appeal rights that expire if missed.

Reviewed August 2026 · Joseph Lancaster, Founder · About the author

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What CP3219A means

The IRS is statutorily notifying you of a proposed deficiency — additional tax, penalties, and interest it intends to assess. If you do not petition Tax Court within the 90-day window (or pay and file a claim for refund), the IRS can assess the tax without further notice.

How CP3219A relates to CP2000

  • CP2000 proposes changes based on document matching — you can agree or disagree.
  • If you do not respond or the IRS rejects your response, CP3219A may follow.
  • See our CP2000 guide for the earlier underreporter notice.

The 90-day Tax Court window

  • Count from the CP3219A mailing date on the notice — not when you opened it.
  • Petitioning Tax Court generally requires filing a petition by the deadline (often with professional help).
  • Paying the tax does not replace petition rights — but strategy depends on your facts; consider professional advice.

Verify with transcripts before you decide

  • Compare CP3219A line items to your return and wage & income transcript.
  • Account transcript shows whether prior CP2000 adjustments or partial agreements posted.
  • Gather documentation for income you dispute — corrected 1099s, missing schedules, identity theft affidavits.

Related IRS notices

Verify on your IRS transcripts

Notices describe what the IRS intends to do — your account transcript shows what actually posted. Start here:

Common questions

Is CP3219A the same as CP2000?

No. CP2000 is a proposed change with a shorter response window. CP3219A is a Statutory Notice of Deficiency with 90-day Tax Court petition rights.

What happens if I miss the 90-day deadline?

The IRS can assess the tax. Your options to dispute in Tax Court without paying first are generally lost — though other remedies may exist depending on circumstances.

Should I agree to CP3219A?

Only if the proposed tax is correct after reviewing your records. If you disagree, the deadline and petition process matter — this is often where professional representation helps.

Does CP3219A mean the IRS will levy me?

Not immediately — it is a deficiency notice. But once tax is assessed and unpaid, balance-due and collection notices can follow. Monitor your account transcript.

Need help responding before collection escalates?

Do It With Me walks through records and paperwork with you — without handing your case to a relief firm.

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