Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)

What you need to do

  • If you want to challenge the deficiency determination, file a petition with the Tax Court.
  • File your tax return immediately (no later than 90 days from the date of the CP3219N), or accept our proposed assessment by signing and returning the Response form.
  • Call us if you think you don’t have to file.

If you want to file a petition with the Tax Court

  • You can download a petition form and rules from the Tax Court’s website.
  • Mail your petition to:
    United States Tax Court
    400 Second Street, NW
    Washington, DC 20217
  • You have 90 calendar days from the date of your CP3219N to file a petition with the Tax Court. The last day to file a petition is stated in your CP3219N. If the CP3219N is addressed to a person who is outside of the United States, the deadline to file a petition with the Tax Court is extended to 150 days from the date of the CP3219N.
  • If you file a petition, attach an entire copy of the CP3219N to the petition.
  • The Tax Court has simplified procedures for taxpayers whose amount in dispute, including applicable penalties, is $50,000 or less per tax year. You can find these simplified small tax case procedures on the Tax Court’s website.

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