The CP3219N is a variant of the statutory notice of deficiency generated by the IRS's Automated Underreporter program. Like the CP3219A and the LTR 3219, it gives you 90 days to petition the United States Tax Court. The deadline is jurisdictional and cannot be extended.
How It Differs
The CP3219N may appear in slightly different processing contexts than the CP3219A, but the legal effect is identical. Both are statutory notices of deficiency under IRC Section 6212. Both start the 90-day (or 150-day if abroad) clock for Tax Court petitions. Both represent the IRS's final administrative act before assessment.
The Path That Led Here
You received a CP2000 proposing changes based on income matching. You either didn't respond, responded but the IRS didn't accept your explanation, or received a CP2501 follow-up that also went unresolved. The CP3219N is the endpoint of that process.
What to Do
Call a tax attorney immediately. You have 90 days from the notice date to file a Tax Court petition. If the original CP2000 was wrong, the CP3219N is proposing the same wrong amount. Filing a Tax Court petition preserves your right to present your case to a judge.
Even if you partially agree with the proposed changes, filing a petition protects your rights on the disputed portion. You can settle with the IRS through the Tax Court process.
Do not call the IRS to negotiate. The examination function has lost jurisdiction. The only path is Tax Court or acceptance.
If you've received a CP3219N, call us today at (813) 229-7100. The 90-day clock is running.