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Letter 3219 – Statutory Notice of Deficiency

By August 7, 2023No Comments

Letter 3219 – Statutory Notice of Deficiency
An IRS Letter 3219 is also known as a “Statutory Notice of Deficiency” or “90-Day
Letter.” It is a significant and formal communication sent by the Internal Revenue
Service (IRS) to inform taxpayers of proposed changes to their tax return that will result
in additional tax liabilities. The purpose of this notice is to provide the taxpayer with a

final opportunity to dispute the proposed changes before the IRS assesses the
additional tax and begins collection actions.
Key points about IRS Letter 3219:

  1. Issuance: The IRS issues Letter 3219 after completing an examination (audit) of
    the taxpayer’s tax return and identifying discrepancies or issues that lead to a
    proposed increase in tax liability.
  2. 90-Day Window: The notice gives the taxpayer 90 days to either agree with the
    proposed changes and pay the additional tax or file a petition with the U.S. Tax
    Court to contest the IRS’s findings. If the taxpayer chooses not to respond within
    the 90-day period, the IRS will proceed with the assessment of the proposed tax
  3. Statutory Notice of Deficiency: Letter 3219 is referred to as a “Statutory Notice of
    Deficiency” because it is required by law under Internal Revenue Code (IRC)
    Section 6212(a) to notify the taxpayer of the IRS’s intention to assess additional
  4. Petitioning the Tax Court: If the taxpayer disagrees with the proposed changes
    and wants to challenge them, they must file a petition with the U.S. Tax Court
    within the 90-day period mentioned in the notice. The Tax Court provides an
    independent forum for resolving tax disputes between taxpayers and the IRS.
  5. Consequences of Not Responding: If the taxpayer fails to respond within the 90-
    day window, the IRS will assess the proposed tax changes, and the taxpayer will
    receive a Notice of Deficiency (CP3219N). The IRS can then take collection
    actions to collect the assessed tax, such as placing liens on the taxpayer’s
    property or initiating wage garnishments.
    Receiving IRS Letter 3219 is a crucial moment in the tax dispute process, and
    taxpayers should take it seriously. If you receive this notice, it is advisable to seek
    professional advice from a tax attorney or a tax professional experienced in handling
    IRS disputes. They can guide you through the appropriate course of action, whether it
    involves resolving the matter with the IRS or filing a petition with the U.S. Tax Court if
    you disagree with the proposed changes.

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