The CP3219A is the statutory notice of deficiency generated by the IRS's Automated Underreporter (AUR) program. It's the same legal document as the LTR 3219, just generated through a different process. It carries the exact same 90-day deadline and the exact same consequences if you miss it.
Most CP3219A notices arrive after a CP2000 that wasn't resolved. The IRS proposed changes to your return, you didn't respond or your response didn't satisfy them, and now they're moving to the final step before assessment. This is the last chance to challenge the proposed changes in Tax Court before the tax becomes final.
How You Got Here
The typical path to a CP3219A runs like this. The AUR system identified an income discrepancy and generated a CP2000. You either didn't respond within 30 days, or you responded but the IRS didn't accept your explanation. They may have sent a CP2501 follow-up. Eventually, the system exhausted its administrative process and generated the CP3219A.
Every step along that path was an opportunity to resolve this without a statutory notice. Those opportunities are gone now. You're at the final station.
The 90-Day Deadline
You have 90 days from the date on the CP3219A to file a petition with the United States Tax Court. This deadline is identical to the one on an LTR 3219. It is jurisdictional and cannot be extended. If you're outside the country, you get 150 days.
Count the days from the notice date, not from when you received it. If the notice is dated March 1 and you didn't get it until March 10, you've already used 10 of your 90 days. Mail delays are your problem, not the IRS's.
Why You Should Still Fight
Remember how the CP2000 process works: it's an automated comparison. The IRS computer matched numbers without context. If the original CP2000 was wrong, the CP3219A is proposing the same wrong amount. The fact that you didn't respond earlier doesn't mean you owe the money.
I've seen CP3219A notices proposing $25,000 in additional tax where the actual amount owed was zero. Stock sales with unreported basis. Income that was properly reported on a different line. 1099s issued in error. Filing a Tax Court petition preserves your right to present these arguments to a judge.
Even if you partially agree with the proposed changes, filing a petition lets you contest the portions you disagree with while accepting the rest. You can settle with the IRS through the Tax Court process, which often produces better results than the automated system.
What to Do Right Now
Call a tax attorney today. Preparing a Tax Court petition requires reviewing the proposed deficiency, gathering documentation, analyzing the IRS's positions, and drafting a legal document that preserves all of your arguments. That takes time, and your 90-day clock is already ticking.
Do not call the IRS to negotiate. The examination function has lost jurisdiction. Do not send another response to the AUR unit. The administrative process is over. The only path forward is Tax Court or acceptance.
Call us at (813) 229-7100. We file Tax Court petitions regularly and we can tell you whether yours is worth fighting.