A Notice of Deficiency (CP3219A) is the IRS’s legal notice that it plans to assess additional tax because your filed return does not match information reported by employers, banks, or digital platforms.
Once the notice is issued, the IRS must wait 90 days before assessing the tax. That window is your chance to fix errors, submit documents, or petition the U.S. Tax Court.
Most taxpayers receive CP3219A after the IRS finds unreported income, denies credits, or questions filing status. Some notices may contain errors such as duplicate 1099s, incorrect platform totals, or dependency and Head of Household disputes. Addressing the issue early prevents forced assessment, penalties, and collections.
The notice is time-sensitive. There are no extensions. Acting promptly protects your rights and preserves your options for resolving the issue.
How to Respond to IRS Notice CP3219A?
You have 90 days to respond. This deadline is strict. The IRS does not grant extensions. If you miss it, the tax becomes final.
Start by reading the first page of the notice. It shows what changed. The IRS usually flags income mismatches, filing status issues, or disallowed credits.
Compare your original return to the IRS Proposed Changes. Look at each income item: W-2s, 1099s, 1099-K forms, and platform-reported earnings. Review dependents and any claim for Head of Household status. Make sure every figure matches your records.
If something seems off, gather supporting documents. Use W-2s, 1099s, brokerage statements, custody records, or proof of support for dependents. Clear documentation is the fastest way to correct an error.
Once you understand what happened, choose your path:
- Sign Form 5564 if you agree.
- Submit documents if the IRS data is wrong.
- Petition the U.S. Tax Court if you disagree and want full protection.
A professional review is worth it in complex or high-risk cases. Examples include significant income differences, disputed dependents, or complex issues involving crypto, gig work, or marketplace reporting.
What to Do When You Receive a Notice of Deficiency?
The CP3219A is not a standard balance-due notice. The IRS issues this because they cannot legally charge you additional tax without giving you a chance to challenge it in court. This step is required under IRC sections §§6212 and 6213. Until the response window closes, the IRS cannot finalize the additional tax.
Most CP3219A notices stem from one issue: mismatched data. Employers, banks, and digital platforms report income directly to the IRS. If the reported amount is higher than what you filed, the system flags it. Credits and filing status can also trigger the notice.
| Notice Type | Purpose | Action Required |
|---|---|---|
| CP14 / CP501 | Billing notice for tax you admitted you owe. | Pay or set up a plan. |
| CP2000 | Preliminary proposal of changes (comes before CP3219A). | Respond within 30 days. |
| CP3219A | Statutory Notice of Deficiency. Final proposal. | Petition Tax Court or Sign Waiver. |
CP3219A notices sometimes contain errors such as duplicate 1099s, incorrect totals, or misclassified filing status. These can be corrected, but only if you respond within the allowed window.
If you act on time, the IRS reviews your documents before assessing anything. If you do not respond, the proposed tax becomes final and the path to fix errors becomes longer and more limited.
How to Fill Out Form 5564 (Deficiency Waiver)
Form 5564 is the waiver attached to CP3219A. You should use it only if you fully agree with the IRS Proposed Changes. Signing it tells the IRS that the numbers are correct. Once signed, the IRS can assess the tax immediately.
Do not sign the form if you disagree with any part of the proposed changes. If income is wrong, if withholding is missing, or if the IRS relied on inaccurate platform data, you must dispute the notice instead of signing the waiver.
Follow these steps to complete the form:
- Verify your name, address, and taxpayer identification number.
- Review the IRS Proposed Changes computation on the notice.
- Confirm every income item with W-2s, 1099s, brokerage statements, or platform summaries.
- Check any changes to credits or filing status.
- Sign the waiver only if all amounts match your records.
- Mail or fax the form using the instructions printed on your notice.
Once the IRS receives the signed form, it assesses the tax. After assessment, you will start receiving collection notices. At that point, your options shift to payment plans, penalty relief, or settlement programs.
Signing Form 5564 is a serious decision because it gives the IRS full authority to lock in the tax immediately. Only sign it if you are sure the figures are accurate.
Side note: The official form comes as part of the mailed CP3219A notice. The safest way to get Form 5564 is to use the copy enclosed in the letter you received.
Your Options After Receiving CP3219A (Agree, Dispute, or Petition)
You must choose one of these three options before the 90 days expire.
Option 1: Agree and Pay (Sign Form 5564)
Use this option only if the IRS numbers are correct. Signing the waiver allows the IRS to assess the tax immediately. Once assessed, you will receive new notices showing the balance due.
Penalties and interest continue to grow until the balance is paid in full. If you cannot pay in full, you can request a payment plan, apply for penalty relief, or explore settlement programs such as an Offer in Compromise.
Sign only if you are certain the changes are accurate, but keep in mind that it removes your right to dispute the issue later.
Option 2: Dispute by Providing Additional Information
Choose this option if the IRS Proposed Changes are based on incorrect or incomplete data. Common issues include missing withholding, duplicate 1099s, incorrect platform totals, or dependents who were correctly claimed.
Helpful documents include corrected W-2 or 1099 forms, platform statements, brokerage reports, and proof of custody or support. In some cases you may need to file Form 1040-X, which is an amended return. The IRS may accept your documentation and adjust the numbers before assessment.
This is the right choice if the notice contains factual errors.
Option 3: Petition the U.S. Tax Court
Petitioning the Tax Court is the strongest protection. You do not need to pay the disputed amount to file. Once the petition is submitted, the IRS is blocked from assessing or collecting the tax until the case is resolved.
After filing, your case is usually reviewed by an appeals officer. Many cases settle at that stage. A trial happens only if the issues cannot be resolved through appeals.
Use this route if you disagree with the IRS’s findings and want your rights protected while the dispute is reviewed.
What Happens If You Don’t Respond to a Notice of Deficiency?
If you do nothing, the IRS finalizes the proposed tax at the end of the response period. Once assessed, the amount becomes a legally enforceable tax debt. You also lose your right to bring the case to Tax Court later.
After assessment, the IRS begins collections. The process escalates in predictable steps:
- Wage garnishment through your employer
- Bank levy on checking or savings accounts
- A federal tax lien that affects credit and property
- Seizure of future refunds
Fixing mistakes becomes significantly harder at this stage. Your main option is Audit Reconsideration, which is slower and not guaranteed. You must present strong documentation to reopen the issue.
Interest continues to grow daily until the full balance is paid or resolved.
How to Reduce or Resolve the Assessed Debt (If You Agree or the IRS Assesses Automatically)
Once the IRS assesses the tax, your focus shifts to resolving the balance. Several programs can reduce the balance, pause collections, or lower penalties. The right option depends on your income, expenses, and financial stability.
- Installment Agreement: You pay the balance monthly. Streamlined plans are available if your total debt is within current IRS limits.
- Offer in Compromise: The IRS may settle the debt for less than the full amount if your income and assets show that paying in full is not realistic.
- Currently Not Collectible status: The IRS pauses collection if your income is too low to cover basic living costs. Penalties and interest continue, but garnishment stops.
- Penalty Abatement: You may qualify if you have reasonable cause or a clean filing history.
- Audit Reconsideration: Use this only if the IRS assessment contains errors. You must provide documents that the IRS did not receive earlier.
Each option has strict rules, but many taxpayers qualify when their financial situation supports it.
Act Before the IRS Finalizes the Tax
A Notice of Deficiency is time-sensitive but manageable if you act within the 90-day window. The IRS Proposed Changes may be accurate, partially correct, or completely wrong. Your goal is to verify the numbers, gather documents, and choose the option that protects your rights.
Once the IRS assesses the tax, your options narrow. Interest grows, collections begin, and correcting errors takes more work. If anything in the notice looks inconsistent with your records, get a professional review before you sign anything.
If you need help reviewing your CP3219A, you can request a free case evaluation from PrecisionTax. A clear review at the start can prevent larger problems later.
Frequently Asked Questions
How to respond to IRS notice CP3219A
Read the IRS Proposed Changes and compare them with your records. If everything is correct, you may sign Form 5564. If any item is wrong, send documentation or file a Tax Court petition before the deadline.
What to do when you receive a notice of deficiency
Identify what the IRS believes is incorrect. Review income, credits, and filing status. Check all W-2s, 1099s, 1099-K forms, and dependent information. Respond before the deadline so the IRS does not finalize the tax.
How to fill out a deficiency form
Use Form 5564 only if every figure on the notice is accurate. Verify your information, confirm the Proposed Changes, and sign the waiver. Mail or fax it using the instructions on the notice.
What happens if you don't respond to a notice of deficiency?
The IRS assesses the tax and begins collections. You lose your right to petition the Tax Court. Fixing errors becomes harder, and interest continues to grow.
Can I dispute a notice of deficiency?
Yes. You can send supporting documents or file a Tax Court petition before the deadline.
Can I file an amended return instead of signing Form 5564?
Yes. Form 1040-X is appropriate when your original return needs corrections. The IRS may accept the amended return before assessment.
Does CP3219A mean I am being audited?
No. It is a proposed change based on mismatched data, not a full audit. It is a legal notice that gives you a chance to dispute the changes.
Can I stop IRS collections by filing in Tax Court?
Yes. Filing a petition blocks assessment and collections until the case is resolved.
Is the IRS always correct in a deficiency notice?
No. Errors are common. Duplicate forms, platform reporting issues, missing withholding, and dependency disputes occur frequently. Documentation is the best way to correct these mistakes.