What This Letter Means
Letter 3279C is the IRS's final determination on your request for relief from joint and several liability, usually called innocent spouse relief. It goes to the requesting spouse, the person who asked for relief. It tells you whether the IRS allowed full relief, allowed partial relief, or denied relief. It also explains your Tax Court rights.
The "C" version comes from the IRS's centralized innocent spouse unit. Field examiners send Letter 3279, which does the same job. The other spouse gets a separate final determination letter.
If You Disagree
You can ask the Tax Court to decide what relief you're entitled to. The petition must be filed no later than the 90th day after the IRS mailed this final determination. That deadline is set by law. Calling the IRS or writing back does not extend it.
The Tax Court looks at your case fresh. It decides based on the administrative record from your IRS case, plus evidence that is newly discovered or wasn't available before.
If the IRS also issued a notice of deficiency for the same year, you can contest both in one Tax Court petition. If you already filed a petition on the deficiency, you may be able to amend it instead of filing a new one.
Collection While You Decide
During the 90-day period, and while a timely Tax Court case is pending, the IRS generally can't levy to collect the tax covered by your request.
If Relief Was Granted
Check which years and amounts the relief covers. Keep the letter permanently. The other spouse can ask to take part if a Tax Court case is filed.
Deadlines
- Find the mailing date on the letter.
- Count 90 days. That's your last day to petition.
- Don't wait until the end. A late petition loses the right to Tax Court review.
If you received Letter 3279C and relief was denied or only partly granted, call us at (813) 229-7100.