IRS CP3219A Notice: Statutory Notice of Deficiency

Separate the IRS response from the Tax Court deadline

The notice explains the proposed change, includes Form 5564, and identifies the date by which a Tax Court petition must be filed. A taxpayer may send information to the IRS and try to resolve the issue without petitioning, but that work does not extend the petition deadline.

Calendar the date exactly as printed and keep the full notice. If preserving court rights or evaluating litigation is important, consult a qualified tax attorney promptly. Tavella CPA Group does not provide legal services or represent clients in Tax Court litigation.

Review the proposed adjustment and the supporting information

• Match each proposed item to the filed return and the third-party income documents identified by the IRS.
• Request corrected information from a payer when the payer's report is wrong, while informing the IRS if the correction is pending.
• Prepare a signed explanation and supporting documents for items you dispute, following the notice instructions.
• If you agree, follow the notice instructions for Form 5564 and any required payment or amended-return work.

Coordinate accounting work and legal rights

A CPA can help reconstruct income, basis, expenses, credits, withholding, and tax calculations. Legal counsel can advise on Tax Court procedure, litigation strategy, and legal rights. When both are involved, use one reconciled set of facts, documents, and calculations so the positions do not conflict.

Keep proof of every submission and do not send originals unless specifically required. Continue monitoring mail and account activity for follow-up correspondence.

Records to gather before responding

• The complete CP3219A, all enclosures, and the envelope showing delivery information
• Any earlier CP2000, Letter 2030, response, or IRS correspondence about the same issue
• The filed return, schedules, amendments, and proof of filing
• Forms W-2, 1099, K-1, brokerage records, basis support, and corrected payer statements
• Copies and delivery proof for information already sent to the IRS
• A written chronology of contacts, submissions, and unresolved items

Where CPA help may be useful

A professional review can help organize the facts and calculations, but it cannot guarantee an IRS decision, penalty result, payment arrangement, appeal outcome, or litigation result. Depending on the agreed scope, support may include:

• Reconcile the proposed changes to the return and source records
• Prepare supported tax calculations and response workpapers
• Organize records for an IRS response or for counsel's review
• Communicate with the IRS when authorized and within the engagement scope
• Coordinate factual and accounting support with the taxpayer's legal counsel