IRS Letter 3219: Notice of deficiency

Letter 3219. Notice of deficiency.

Letter 3219 is a statutory notice of deficiency. It proposes a tax change and starts the period in which a taxpayer may file a petition with the United States Tax Court under Internal Revenue Code section 6213.

General information from the Law Office of Alexander Powell, PLLC. It is not legal advice, and it is not a substitute for the notice itself.

On the paper

Find the exact last day to file a Tax Court petition printed in the notice. Keep the envelope and every page.

Find the date printed on your notice or letter. The paper notice and the current official IRS instructions control, even where this page differs.

General next steps

Compare each proposed adjustment with the return and supporting records.
If you disagree, read the petition instructions and confirm the filing deadline from the notice itself.
If you agree, follow the IRS instructions for payment or other response after considering the notice’s procedural instructions.

Timing

Internal Revenue Code section 6213(a) sets a period of 90 days to file a Tax Court petition, or 150 days where the notice is addressed to a person outside the United States, measured from the mailing of the notice. The printed date controls, and the IRS cannot extend this period.

What this page cannot tell you

A Tax Court deadline is fact-specific. Do not assume that reading this page pauses or preserves any deadline.

Official sources

If anything on this page differs from your notice or from current IRS instructions, follow the notice and the IRS.

Questions after reading the letter?

You can ask the Law Office of Alexander Powell, PLLC to consider a consultation about any IRS or tax letter. Requesting a consultation does not make Mr. Powell your lawyer, provide legal advice, or protect a deadline. Representation begins only after a conflict check, after the firm agrees to the matter, and after both sides sign a written engagement agreement.

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