CP3219A: A Statutory Notice of Deficiency

The IRS issues CP3219A when it proposes to adjust tax based on information reported by employers, banks, brokers, or other third parties and the disagreement was not resolved earlier.

The notice explains the proposed change and encloses Form 5564. It is not merely a payment reminder. It creates a path to challenge the deficiency in U.S. Tax Court before paying, provided a timely petition is filed.

You may still send the IRS additional information during the response period, but that work does not stop or extend the Tax Court petition date. Run the administrative response and deadline protection as two separate tracks.

CP3219A usually follows an unresolved CP2000. If you are still at the underreporter-proposal stage, start with our CP2000 response guide.

Read the current IRS explanation for this notice at IRS.gov. The instructions and address printed on your own letter control.

1. 1Circle the Tax Court petition date and create redundant calendar reminders.
2. 2Compare CP3219A with the earlier CP2000 or underreporter correspondence and your prior responses.
3. 3Rebuild the disputed items from source documents, including basis and duplicated income.
4. 4Decide promptly whether an administrative resolution is realistic and whether petition advice is needed.
5. 5Do not sign Form 5564 until you understand what rights and adjustments you are accepting.

The IRS may still consider additional information during the response period. A complete response can resolve issues such as missing stock basis, income reported twice, corrected information returns, or identity theft.

If the dispute cannot be resolved in time, a timely Tax Court petition may preserve prepayment review. Taxstra can handle IRS-level tax representation; advice about filing and litigating a Tax Court case may require qualified Tax Court counsel.

• Complete CP3219A and enclosed Form 5564
• Earlier CP2000, response, and IRS follow-up letters
• Filed return and account transcript for the year
• Corrected W-2s, 1099s, K-1s, or payer statements
• Brokerage statements and cost-basis records
• Proof of every prior upload, fax, or mailed response

This notice deserves rapid professional attention because it combines tax reconstruction with a legal deadline. The value is not merely writing a letter; it is preserving options while testing the IRS calculation.

• The proposed deficiency is significant.
• Stock, crypto, business income, K-1s, or duplicated wage reporting is involved.
• A prior CP2000 response was ignored or rejected.
• The petition date is approaching.
• You need coordinated CPA representation and Tax Court counsel.

Taxstra can review the notice, reconcile it to the return and IRS records, and handle authorized IRS contact through our notice defense service. If the letter is part of a larger unpaid-tax problem, see our tax relief service or how our IRS tax resolution services work.