CP3219A
hard deadline · rights expireStatutory Notice of Deficiency
The formal determination that you owe more tax — the ninety-day letter, and your one ticket to Tax Court without paying first.
150 days if the notice is addressed to a person outside the United States. Saturday, Sunday and a District of Columbia legal holiday cannot be the last day. If the IRS printed a later date than the statute allows, the printed date controls in your favour.
Can it be extended? No. The IRS says so on its own page: replying may resolve things, but it does not extend the time to file a petition.
If it passes. The IRS assesses the proposed change and bills you. What is left is audit reconsideration, an offer in compromise on doubt as to liability, or paying in full and suing for a refund. Prepayment judicial review is gone.
Why you got it
You did not respond to a CP2000, or the IRS could not accept what you sent.
What rights it carries
Petition the United States Tax Court under IRC § 6213(a). Talking to the IRS during the 90 days preserves nothing on its own.
Do you have to respond?
Responding to the IRS is optional. Filing the petition, if you want Tax Court, is not.
The mistake people make
Mailing documents to the IRS instead of filing a petition. It feels like progress and it is not.
Letter 531 and Letter 3219 are the same legal event from a different IRS function — examination rather than the underreporter stream. The 90 days is identical.
If crypto is why this arrived, the number on it is probably wrong.
Your exchange reports what you sold for and leaves the cost box blank, so any figure the IRS computes from it treats every coin as though it cost you nothing. Rebuild the basis from your own transaction history — free — and see the real number before the deadline above runs out.
Notices that arrive around this one
CP11 — The IRS corrected something on your return and now says you owe money. CP12 — The IRS corrected your return and you are owed a refund, or your refund amount changed. CP23 — You claimed more in estimated tax payments than the IRS has on record, and now you owe. CP14 — Your first bill. Tax has been assessed and it has not been paid.Every notice in the library → Not sure it is really from the IRS? →
Sources: IRS — Understanding your CP3219A notice · IRC § 6213 · IRC § 6212. Retrieved 2026-08-28. Where the IRS publishes no day count we say so rather than repeat a number we cannot source — the date printed on your own notice is the one that governs. ClearBasis is tax software, not a tax adviser, and this is information rather than advice.