Glossary

Notice CP3219A (statutory notice of deficiency)

Notice CP3219A is the statutory notice of deficiency issued after a CP2000 or audit goes unresolved, stating the tax the IRS intends to assess and starting the 90-day period to petition the Tax Court.

How it works

CP3219A is the statutory notice of deficiency the IRS issues after a CP2000 or audit goes unresolved. It states the tax the IRS intends to assess and starts the 90-day period to petition the Tax Court. The deadline cannot be extended and the court cannot accept a late petition. After 90 days without a petition, the tax is assessed and collection begins.

Why it matters

This is the deadline that separates disputing before paying from paying and suing for a refund.

Related: notice of deficiency, Tax Court petition.

Guides that cover notice CP3219A

Related terms

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Where this comes up in our work

IRS audit defense

From the first notice to the last letter, with a power of attorney so the IRS talks to us.

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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.

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