IRS Notice CP3219A · Statutory Notice of Deficiency (90-Day Letter)

A CP3219A is the 90-day letter. The deadline cannot be extended.

This is the Statutory Notice of Deficiency. You have exactly 90 days to petition the U.S. Tax Court — there is no extension, ever. After it lapses, the tax is assessed.

90 days — strict

Typical deadline

Tier 3

from $1,495

15 min

Free triage call

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What it is

What a CP3219A actually means

A CP3219A is the formal notice that the IRS intends to assess additional tax, usually after an unresolved CP2000. It is the legal prerequisite to assessment and the trigger for your right to petition the Tax Court.

The 90-day period (150 days if addressed outside the U.S.) is statutory and absolute. Filing a Tax Court petition preserves your right to dispute the tax without paying first. Missing it means the deficiency is assessed and your remedies narrow sharply.

Why you might have received one

A prior CP2000 wasn't resolved in time
The IRS rejected your CP2000 response
An examination concluded with a proposed deficiency
Correspondence didn't reach the IRS before assessment

What's at stake

If the 90 days lapse without a petition, the tax, penalties, and interest are assessed and collection begins. The petition deadline is jurisdictional — courts cannot waive it. This is the most time-sensitive notice the IRS sends.

Common mistakes we see

Counting on an extension — none exists for the 90-day period
Mailing a Tax Court petition late — the postmark is the filing date
Assuming you must pay before disputing — a timely petition avoids that
Waiting to gather documents when the petition itself preserves your rights

Transparent, flat-fee pricing

You'll know the cost before we start

No hourly surprises on routine notices. We confirm the tier on your free triage call and put the fee in writing.

Tier 1

$295 flat fee

Simple notices

CP501, CP14, balance-due reminders
Notice review & deadline confirmation
One drafted response letter
Filed on your behalf

Tier 2

$595 flat fee

Underreporter & matching

CP2000, CP2030, AUR notices
Line-by-line reconciliation
Substantiation package assembled
One free follow-up within 90 days

Tier 3

from $1,495 scoped quote

Urgent & high-stakes

CP3219A, CP504, Letter 226-J
Tax Court petition support
Penalty abatement requests
Direct IRS / DOR representation

Tier 4

$350 per hour

Examination & appeals

Full audit representation
Appeals conferences
Complex multi-year matters
Quoted in writing before work begins

Common questions

Before you call us back, read this

Can the 90 days be extended?

No. The period is statutory and jurisdictional. Even a one-day-late petition is dismissed. This is why a CP3219A demands immediate action.

Do I have to pay the tax to dispute it?

Not if you petition the Tax Court within 90 days. A timely petition lets you contest the deficiency before paying. Miss it, and you'd generally have to pay and sue for refund.

Is it too late if I ignored the CP2000?

Not yet — the CP3219A is precisely the window to act. But it is the last one before assessment, so the response must be filed immediately.

Why is this Tier 3?

It can involve drafting and filing a Tax Court petition and direct representation. We scope and quote it in writing on the triage call given the stakes and deadline.