IRS Notice CP3219A
Statutory Notice of Deficiency (AUR)
CP3219A is the 90-day 'ticket to Tax Court' issued when a CP2000 or CP2501 goes unresolved. You have exactly 90 days to petition Tax Court, and the deadline is jurisdictional.
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Notice CP3219A in Plain English
CP3219A is the Statutory Notice of Deficiency issued from the Automated Underreporter (AUR) unit — the 'ticket to Tax Court' that follows an unresolved CP2000 or CP2501. You have exactly 90 days from the date on the notice (150 if outside the US) to petition Tax Court, and the deadline is jurisdictional: miss it by a day, and Tax Court cannot hear the case.
Why the IRS sent you a CP3219A
You received a CP2000 or CP2501, and either did not respond or the IRS rejected your response.
Third-party income data (1099s, K-1s, W-2s) still shows a discrepancy the IRS won't resolve informally.
The proposed assessment includes an accuracy-related penalty of 20% of the underpayment.
What Happens If You Ignore Notice CP3219A
Miss the 90-day window and you must pay the assessment first and sue for refund later. Includes a 20% accuracy-related penalty on the underpayment.
Every day you wait, penalties compound, interest accrues, and your options shrink. The IRS does not negotiate well with silence — they escalate.
What To Do About Notice CP3219A
Calendar the 90-day deadline immediately. Petition Tax Court or respond in writing with documentation. Screen for reasonable-cause penalty relief.
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Calendar the 90-day deadline the day you receive the notice — it does not extend for weekends, holidays, or hardship.
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Petition the U.S. Tax Court by the 90-day date if you want to litigate without paying first; the filing fee is $60 and the form is short.
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If Tax Court is not the right forum, respond in writing with documentation before day 90; even a late response can be treated as a claim for audit reconsideration after assessment.
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Screen for reasonable-cause relief from the accuracy penalty; many CP3219A penalties are eliminated when the taxpayer relied on a preparer or brokerage 1099 in good faith.
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If assessment has already happened, file Form 843 for penalty abatement and Form 4549 audit reconsideration to contest the tax itself.
A Senior Tax Attorney's Take on CP3219A
The 90-day statutory notice is one of the sharpest deadlines in federal tax law — and one of the most powerful, because Tax Court jurisdiction gives you leverage the IRS respects. Filed properly, most CP3219A cases settle in Appeals before ever seeing a judge.
Call (877) 829-5267Costly Mistakes People Make With Notice CP3219A
Confusing the 90-day deadline with the IRS's other 30-day deadlines and losing Tax Court jurisdiction.
Filing Tax Court without an alternative proposal ready — the case will often settle in IRS Appeals if a reasonable number is offered early.
Paying the assessment before the 90 days run to 'stop the interest,' which forfeits Tax Court and forces you into the more expensive refund-suit path.
IRS Notices Related to CP3219A
These are the notices the IRS most often sends before, after, or alongside a CP3219A. Read the related ones to understand where you are in the collection sequence.
Tax Resolution Services That Resolve a CP3219A
Senior tax attorneys at McCauley Law Offices use these strategies to stop, settle, or unwind a CP3219A notice.
Challenge unfavorable IRS decisions through the independent Appeals Office.
Professional representation during IRS examinations to protect your interests.
Remove or reduce IRS penalties through first-time abatement or reasonable cause.
Primary Sources & Authority
We cite the underlying IRS publications and statutes so you can verify everything on this page.