The Statutory Notice of Deficiency Notice CP3219A (also referred to as 90-Day Letters), is a taxpayer’s legal notice that the IRS is proposing a deficiency (tax assessment). This notice provides taxpayers with information about their right to challenge proposed IRS adjustments in the United States Tax Court by filing a petition within 90 days on the date of their notice (150 days if the notice is addressed to a person outside the United States). 

If the IRS is proposing to adjust the amount of tax you owe, you will typically be sent a statutory notice of deficiency informing you of the proposed change. Because this notice provides you with the right to challenge the proposed adjustment in the Tax Court without first paying the proposed adjustment, the statutory notice of deficiency is often considered “your ticket to the Tax Court.” 

The IRS is required to send a statutory notice of deficiency to a taxpayer’s last known address by certified or registered mail. The last known address is generally the address that appears on your most recently filed and properly processed tax return unless the IRS is given clear and concise notification of a different address. Form 8822, Change of Address, can be used by taxpayers to change their address with the IRS. 

The notice of deficiency must describe the basis for, and identify the amounts (if any) of, tax due. Sometimes, but not always, the IRS includes penalties in the notice of deficiency, but does not include interest.  The IRS will ultimately send a bill for the tax due, interest, and any applicable penalties. 

You received Notice CP3219A because the IRS completed the examination of your tax return and proposed changes to the amount of tax you owe. You have either not responded or have not provided a signed agreement consenting to these changes. Without your consent, the IRS cannot assess the proposed deficiency without first providing you an opportunity to challenge these adjustments by filing a petition with the Tax Court.