CRITICAL PRIORITY

IRS Notice CP3219A

Statutory Notice of Deficiency

⏱ Deadline: 90 days to petition Tax Court — this deadline cannot be extended

The IRS has determined that you owe additional taxes and this is their formal legal notice of that determination. You have exactly 90 days to either pay and agree, or petition the United States Tax Court to challenge it. This deadline is statutory — it cannot be extended under any circumstances.

Common Causes

Your Options

Petition Tax Court (within 90 days)

File a petition with the US Tax Court to challenge the assessment before paying. You do not need a lawyer to petition Tax Court.

Pay and Agree

Sign the agreement form enclosed with the notice and pay the amount owed.

Contact IRS Appeals

Before petitioning Tax Court, you may be able to resolve through the IRS Independent Office of Appeals.

⚠️ Do Not Ignore This Notice: Missing the 90-day deadline permanently forecloses your right to dispute this in Tax Court without first paying the tax. This is one of the most important deadlines in all of tax law.
💡 Pro Tip: Even if you ultimately agree with the assessment, filing a Tax Court petition preserves your rights and gives you time to negotiate. Many cases settle before trial. The 90-day window is absolute — do not miss it.

Frequently Asked Questions

What is a CP3219A notice?

A CP3219A is a Statutory Notice of Deficiency — the IRS's formal legal notice that you owe additional taxes. You have 90 days to petition Tax Court or the assessment becomes final.

Can I extend the 90-day deadline on a CP3219A?

No. The 90-day deadline is statutory and cannot be extended under any circumstances. Missing it permanently waives your Tax Court rights.

Do I need a lawyer to respond to a CP3219A?

No. You can petition Tax Court yourself (pro se). However, given the stakes, consulting an Enrolled Agent or tax attorney is strongly recommended.

Ready to resolve your CP3219A?

IRS Pilot walks you through your options step by step — built by a licensed Enrolled Agent.

Get Full Guidance — from $59 See How It Works

This page provides general information only and does not constitute legal or tax advice. Built by Tyrone J. Taylor, EA — Enrolled Agent, NTPI Fellow.