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IRS notice decoder · Notices of deficiency

CP3219A: notice of deficiency with a Tax Court deadline

A CP3219A is a notice of deficiency. It carries a Tax Court petition deadline the IRS says it can't extend. Read it today.

By the Carry Forward Learning team Reviewed by Hunter Nottingham, JD, CPA

Checked Review by

CheckedOct 19, 2026

What a CP3219A means

A CP3219A is a statutory notice of deficiency. The IRS has decided your income tax needs adjusting because income reported by others didn't match your return, and it explains how to challenge that, including in the Tax Court. source 1

The Taxpayer Advocate Service calls it your ticket to the Tax Court: it lets you dispute the amount there without paying it first. source 2 It usually follows a CP2000 that wasn't resolved. source 3

This is the one notice in the matching series where the date matters most. Everything else can be fixed with a letter. This date can't be moved.

The date that counts

If you want the Tax Court to hear it, the petition has to be filed by the date listed on the notice. The IRS says the court can't consider a late petition, that you can't get an extension, and that working with the IRS during the response period doesn't extend the Tax Court deadline. source 1 The time comes from federal law, which counts from the mailing of the notice. source 4

For context, section 6213 of the Code gives 90 days from the mailing of the notice, or 150 days if the notice is addressed to someone outside the United States. The date printed on your notice is the one to go by. source 4

Why people get one

  • A CP2000 went unanswered, or the reply didn't settle every item. source 3
  • You didn't sign an agreement to the proposed changes. source 2

First steps

  1. Find the petition date on the notice and write it on your calendar today. source 1
  2. Check your IRS online account, typed in yourself at irs.gov, to see the notice and your balance or payments.
  3. Read the enclosed report and compare it with any CP2000 you got. The IRS says the amount on Form 5564 can differ from an earlier notice. source 1
  4. If you agree, sign and send Form 5564. source 1
  5. If you disagree, send your documents and a signed statement promptly, and if you want the Tax Court to decide, file a petition by the date on the notice, following its instructions. source 1
  6. If a payer's form is wrong, ask the payer for a corrected form or a statement and send it to the IRS when you get it. source 1

What not to do

  • Don't assume a letter to the IRS protects your Tax Court date. It doesn't. source 1 source 2
  • Don't wait for the IRS to answer before deciding about a petition.
  • Don't pay or send documents through a link or phone number in an unexpected email or text. Use irs.gov, typed in yourself.
  • Don't ignore it. With no reply and no petition, the IRS says it will assess the changes and send a bill. source 1

Where it sits

When income on your return doesn't match the forms

The matching program's path, from a question about a form to a court deadline.

  1. CP2501A question about a mismatch
  2. CP2000A proposed change, not a bill
  3. CP3219ANotice of deficiencyYou are here
  4. ↳Tax Court petition, by the date printed on the notice
  • Comes before CP2000 The proposed change that comes before the notice of deficiency.
  • Related CP2501 The earlier information request in the same matching program.

Keep reading

Questions

Can I get an extension on a CP3219A?

No. The IRS says there's no extension, and that working with it doesn't extend the Tax Court deadline. Send any information as soon as possible. source 1

Do I have to file a Tax Court petition?

Not necessarily. The IRS says you may be able to settle it by replying with Form 5564, documents and a signed statement, but the Tax Court deadline still applies. source 1

What if I miss the Tax Court date?

The court can't consider your case, and the proposed tax, plus any penalties and interest, will be assessed. source 2

Will I owe interest on a CP3219A amount?

Yes. The IRS says interest accrues on the unpaid balance until it's paid in full. source 1

Sources

  1. IRS, Understanding your CP3219A notice (updated October 2, 2026) (external site) checked Oct 19, 2026
  2. Taxpayer Advocate Service, Notice CP3219A, Automated Underreporter Notice of Deficiency (updated May 12, 2026) (external site) checked Oct 19, 2026
  3. Taxpayer Advocate Service, Notice CP2000 (updated June 10, 2026) (external site) checked Oct 19, 2026
  4. 26 U.S.C. section 6213 (deficiency procedures; math and clerical errors) (external site) checked Oct 19, 2026

Every rule on this page comes from the IRS page in the list, read on the date shown. Your notice itself is the final word on its own dates and amounts.

Figures on this page

Checked

Every figure above comes from the source listed here, with the date we checked it and the date it is due for a re-check.

  • IRS procedure: tax court petition days cf-2026:irs_procedure.tax_court_petition_days
    IRC 6213(a) checked 2026-10-19, review by 2027-01-19