What Is an IRS CP3219A (Statutory Notice of Deficiency)?

IRS Notices Explained
Written by Enrolled Agent
Reviewed by Enrolled Agent

A CP3219A is a Statutory Notice of Deficiency. It’s the IRS’s formal notice that it intends to assess additional tax. You have a limited window to respond or petition U.S. Tax Court before the IRS makes the assessment final. Here’s what it means and how to protect your rights.

Quick Answer

The CP3219A is the IRS’s Statutory Notice of Deficiency. It follows proposed adjustments (often after a CP2000) when agreement wasn’t reached. The notice explains the IRS’s proposed changes and gives you a defined period to respond or file a petition in Tax Court before the IRS assesses the tax.

Important: This notice starts a strict, time-limited response period. Acting within the window preserves your right to challenge the IRS’s position before assessment.

Why You Received a CP3219A

  • You received a proposed change (e.g., CP2000) and didn’t agree or fully resolve it.
  • The IRS believes additional tax is due based on third-party information or adjustments.
  • Prior correspondence didn’t settle the differences, so the IRS is moving toward assessment.

The CP3219A is not a casual reminder. It’s the IRS’s formal step before assessing additional tax.

What the CP3219A Means

The notice lays out the IRS position: which items are changing, why, and how your tax, penalties, and interest would be affected. It also explains your options to agree, partially agree, or disagree and how to exercise your right to petition.

This is a legal notice. Missing the deadline can lead directly to assessment of the full amount the IRS proposes.

Your Rights & Timeline

You have a fixed period (printed on the notice) to respond or petition the U.S. Tax Court. Filing a timely petition stops assessment while the court reviews your case. If you resolve the issue with the IRS before petitioning, the matter may not need to go to court.

Preserving your rights depends on timing. Keep the envelope and notice; dates matter.

What to Do Next

Choose the path that matches your situation:

  • Agree: Sign and return the agreement form; arrange payment or resolution options.
  • Partially agree: Indicate which items you accept and which you dispute; include supporting documentation.
  • Disagree: Prepare a response with evidence. If needed, file a timely petition with the U.S. Tax Court to challenge the proposed assessment.

Professional representation helps you evaluate the IRS’s position, assemble documentation, and preserve your rights within the deadline.

Need the full roadmap? See our Complete Guide to Back Taxes in the U.S. for how notices escalate and how resolution works at each stage.

If You Ignore the CP3219A

If you do nothing, the IRS will assess the proposed tax. Once assessed, penalties and interest continue to accrue, and your account can move into collections, including liens and levies if unpaid.

It’s far easier to address issues before assessment than to fight collections after the fact.

How Polaris Can Help

Polaris Tax & Accounting represents taxpayers nationwide through CP3219A and beyond. Our Enrolled Agents review the proposed changes, pull IRS transcripts, prepare evidence, engage with the IRS, and—when necessary—coordinate timely Tax Court petitions with counsel.

Our goal is straightforward: protect your rights, correct inaccuracies, and achieve the most favorable resolution possible before assessment becomes final.

Your Next Step: Get expert help before the deadline passes. Schedule a consultation today.

Related Resources

FAQs

Is a CP3219A the same as an audit?

No. It’s a statutory notice based on proposed changes. You still have rights to respond or petition before assessment.

How much time do I have?

Use the deadline printed on your notice. Acting within that window preserves your right to petition and stops assessment pending review.

Do I need to amend my return?

Not necessarily. The CP3219A process addresses the proposed changes directly. Amending can be strategic in some cases; professional guidance helps you decide.

© Polaris Tax & Accounting. Nationwide Enrolled Agent representation. Educational content only; not a substitute for personalized advice.