USTaxPenaltySaverLetter 3219
CriticalNotice of Deficiency (90-Day Letter)
Statutory notice of deficiency. You have 90 days to petition Tax Court or the tax will be assessed.
Response Deadline
90 days from notice date
Respond before this deadline to avoid additional penalties and enforcement action.
What This Notice Means
Letter 3219 (also known as the "90-day letter") is a formal Notice of Deficiency required by law before the IRS can assess additional tax. This is your "ticket to Tax Court" - you have 90 days (150 days if outside the US) to file a petition with the Tax Court to contest the proposed tax. If you do not petition Tax Court, the tax will be automatically assessed.
Why You May Have Received This
- 1Did not respond to 30-day letter
- 2Disagreed with audit findings
- 3CP2000 adjustment not resolved
Required Actions
Consult a tax professional immediately
Decide whether to petition Tax Court within 90 days
If petitioning, file with US Tax Court before deadline
If agreeing, sign and return the enclosed form
Your Options
Use these calculators to understand your situation and explore resolution options.
Consequences If Ignored
- After 90 days, tax is assessed automatically
- You lose the right to petition Tax Court without paying first
- Must pay tax and sue in District Court or Court of Claims instead
Tips & Best Practices
- The 90-day deadline is statutory and cannot be extended
- Tax Court allows you to contest without paying first
- Free low-income taxpayer clinics can help with Tax Court petitions
- The filing fee for Tax Court is $60
Related Resources
Legal References
Ready to Take Action?
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