IRS Notice CP3219A: What It Means & What to Do
CP3219A proposes a change to your tax based on third-party information and starts a 90-day window to petition the U.S. Tax Court. Learn how to respond.
Written and maintained by Joseph Lancaster, Settlement Officer since January 2013
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Quick answer
What is an IRS CP3219A notice and what should I do?
CP3219A is a notice of deficiency proposing a tax change based on third-party information. Sign Form 5564 if you agree; if not, reply right away and file a Tax Court petition by the deadline on the notice if you want to challenge it.
Who this applies to: People whose return differs from W-2, 1099 or other third-party reports and who received a proposed change.
What can change this answer
- The Tax Court deadline cannot be extended
- Not every item can be challenged in Tax Court
- Replying does not pause the deadline
Recommended next step
Compare the notice with your wage and income transcript before the deadline.
Read the full guideCP3219A means the IRS proposes to change your tax because information from employers, banks or others differs from your return. It is not a bill or an audit, but it gives you a fixed deadline to challenge the change in U.S. Tax Court.
Immediate Steps to Take
- 1Find the Tax Court petition deadline on the notice
- 2If you agree, sign and return the enclosed Form 5564
- 3If you disagree, reply right away with a signed statement and documents
- 4File a Tax Court petition by the deadline if you want the court to decide
What CP3219A means
The IRS found differences between your return and what employers, banks or others reported. CP3219A explains how the proposed amount was calculated and your options. The amount on the enclosed Form 5564 may not match an earlier notice, because not every item can be challenged in Tax Court.
If you disagree
Reply as soon as possible with a signed statement and the information you want the IRS to consider. If the third-party information is wrong, ask the business or person who reported it for a corrected document, and tell the IRS you are waiting for it. The IRS works with you during the 90-day period, but that does not extend your Tax Court deadline.
Filing a Tax Court petition
You have the right to petition the U.S. Tax Court. File by the date on the notice; the court cannot consider a late petition. The Tax Court website explains how to file electronically or by mail.
Frequently Asked Questions
Is CP3219A a bill?
No. It notifies you of a proposed change to your tax and explains how to agree, disagree or challenge it in Tax Court.
Can the IRS extend my Tax Court deadline?
No. The IRS says it cannot extend the time you have to file a Tax Court petition, even while it is reviewing your reply.
What do I send if I agree?
Follow the notice instructions and return the enclosed Form 5564, Notice of Deficiency - Waiver.
Authority Citations
This content is based on the following official IRS sources. All links open in a new tab.
Information current as of 2026. Tax laws change frequently. Verify with official IRS sources before taking action.
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