IRS NoticesCRITICAL URGENCY

Received IRS Letter 3219? You Have 90 Days to Respond

This is a Statutory Notice of Deficiency—your only opportunity to dispute in Tax Court without paying first.

Critical Deadline

90 days (150 days if addressed outside US) to petition Tax Court

Note: Strategy Sessions require a $250 analysis fee, applied 100% toward your final service.

Understanding Letter 3219

IRS Letter 3219, also called a Statutory Notice of Deficiency or '90-day letter,' is among the most important notices the IRS sends. It formally proposes additional tax and gives you 90 days to petition the U.S. Tax Court if you disagree. This is your only opportunity to dispute the assessment in court WITHOUT paying the tax first. Missing this deadline means the tax is automatically assessed and your only option is to pay first, then sue for a refund.

IRS Authority: IRC § 6212, IRC § 6213

What Happens If You Don't Act

✗Automatic assessment if you miss 90-day deadline

✗Loss of right to dispute in Tax Court without paying

✗Only option becomes pay-first, sue-later (refund suit)

✗Full proposed tax, penalties, and interest become due

✗Collection actions can begin immediately after assessment

✗Limited ability to negotiate once assessed

How The Tax Pro Advisor Resolves This

Helping Austin and Leander business owners resolve letter 3219 issues with proven strategies and direct IRS representation.

1File Tax Court petition within 90-day deadline

2Review proposed deficiency for accuracy and errors

3Gather evidence supporting your position

4Negotiate with IRS Appeals before trial

5Represent you in Tax Court if necessary

6Achieve settlement reducing proposed assessment

IRS Forms & Documents We Prepare

Tax Court PetitionDocumentation supporting your positionResponse to Statutory NoticeAppeals request if appropriate

Frequently Asked Questions

What is IRS Letter 3219?

Letter 3219 is a Statutory Notice of Deficiency (also called a 90-day letter) formally proposing additional tax. It's your only opportunity to dispute in Tax Court without paying the tax first.

How long do I have to respond to Letter 3219?

You have exactly 90 days from the date of the notice (150 days if addressed to you outside the U.S.) to file a petition with the U.S. Tax Court. This deadline is absolute and cannot be extended.

Can I settle this for less than I owe?

Yes. After filing a Tax Court petition, most cases settle through IRS Appeals without trial. We negotiate to reduce the proposed deficiency based on facts, law, and documentation.

Related IRS Issues

CP2000 Notice Penalty Abatement Worker Classification

Don't Wait Until It's Too Late

The longer you wait, the fewer options you have. Get a free, confidential consultation to understand your situation and next steps.