IRS CP3219A Notice
If you’re holding an IRS CP3219A, you’re holding a Notice of Deficiency.
It commonly follows a CP2000, when the IRS proposed changes based on information reported to it by employers, banks, brokers, or other third parties and the disagreement wasn’t resolved.
The CP3219A states the IRS’s proposed deficiency and gives you a last day to file a petition with the U.S. Tax Court.
Start with that date.
Is a CP3219A a Notice of Deficiency?
Yes. A CP3219A is a Notice of Deficiency.
You may also hear it called a statutory notice of deficiency, stat notice, NOD, or sometimes SNOD. Those are practitioner shorthand for a Notice of Deficiency. The IRS notice itself is what matters.
CP3219A is the particular Notice of Deficiency commonly used when an IRS information matching dispute has progressed beyond the CP2000 stage.
Why Did the IRS Send a CP3219A?
A CP3219A often comes after a CP2000.
The IRS received information that didn’t match what was reported on your return, proposed a change, and the issue wasn’t resolved during the CP2000 process.
The CP3219A is different from the CP2000. It is a Notice of Deficiency.
What Should I Look for on the Notice?
- Notice date
- Tax year involved
- Changes the IRS determined
- Amount of the proposed deficiency
- Last day to file a Tax Court petition
That last date is the first thing I want to see when someone brings me a CP3219A.
What Can You Do With a CP3219A?
A CP3219A gives you a formal opportunity to dispute the IRS determination in U.S. Tax Court.
What comes next depends on whether you agree with the proposed changes, what happened during the CP2000 process, and the date shown on the notice.
For the full explanation of what a Notice of Deficiency means and the filing period that applies:
If I Review a CP3219A
I start with the notice, but I don’t stop there.
I want to see what the IRS originally proposed in the CP2000, how you responded, what information was provided, and what changed between that proposal and the Notice of Deficiency.
If the matter moves to Tax Court, I am admitted to practice before the United States Tax Court as a non-attorney practitioner.
I’ve been using this terminology for a long time. In IRS Secrets Revealed: How to Survive IRS Audit, Collections & Appeals, I explain the 90-day letter as a statutory Notice of Deficiency, or NOD, and where it fits in an IRS dispute.
Frequently Asked Questions
Is a CP3219A the same as a CP2000?
Is a CP3219A a bill?
What if the date on my CP3219A has already passed?
Received a CP3219A?
Start with the notice.
Bring the CP3219A, the CP2000 that came before it if you have it, your response to the CP2000, and anything else the IRS sent about the proposed changes.
I’ll look at what the IRS originally proposed, what you disputed, what the IRS ultimately determined, and the date shown on the notice.