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Your IRS Letter 3219 Notice of Deficiency, Explained
Also called: 90-Day Letter, Statutory Notice of Deficiency (audit track)
Last reviewed 2026-07-12
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What this notice usually means
Letter 3219 is not a bill. It is the IRS's formal legal notice that it is proposing a change to your tax after finishing an audit of your return that was handled by mail. You get this letter because the IRS examined your return and proposed changes that you either have not responded to or have not signed off on. This letter opens a strict window to petition the United States Tax Court before the IRS assesses anything. You can file a petition by the date on your letter, generally 90 days, or 150 days if your letter is addressed to you outside the United States. The Tax Court and the IRS decide what happens next.
See every source line for this notice
“is a taxpayer’s legal notice that the IRS is proposing a deficiency.”
“You received a Letter 3219 because the IRS completed the examination of your tax return and proposed changes to the amount of tax you owe.”
“If you agree, sign and return Form 5564, Notice of Deficiency-Waiver, which was provided with the Letter 3219, Notice of Deficiency.”
What to do now
- 1
Find your petition deadline
Your letter lists the exact date, generally 90 days from the letter date, or 150 days if addressed outside the United States. That printed date controls.
- 2
Review the complete audit report enclosed with your letter
Compare it with your own return and decide whether you agree with the proposed changes or want to challenge them.
- 3
Sign Form 5564 if you agree
Form 5564, Notice of Deficiency-Waiver, comes with your letter. Signing and returning it lets you agree to the changes without going to Tax Court.
- 4
File a Tax Court petition if you do not agree
A petition goes to the United States Tax Court itself, not the IRS, within the 90-day or 150-day period on your letter. There is a filing fee, but you can ask the court to waive it.
- 5
Get help preparing your response
Free tax clinics and legal aid offices can help. They can review your audit report or help you file a Tax Court petition.
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You generally have 90 days from the date of your letter to petition the Tax Court. You get 150 days if your letter went to an address outside the United States. The IRS cannot extend this deadline, even if you are also talking with the IRS.
“These letters provide taxpayers with information about their right to challenge proposed IRS adjustments in the United States Tax Court by filing a petition within 90 days of the date of their notice”
“To petition the Tax Court, you must send your petition to the United States Tax Court (not the IRS) within the 90-day (or 150-day) period shown on your notice.”
“If you miss the deadline, the Tax Court can’t consider your case and the proposed tax will be assessed, along with any applicable penalties and interest.”
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Sources
- IRS Taxpayer Advocate Service (taxpayeradvocate.irs.gov)Retrieved 2026-07-12
Last reviewed 2026-07-12
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