IRS NOTICE REFERENCE

Understanding your CP3219A notice

Factual reference for CP3219A. General information only — not legal or tax advice.

General information only. Not legal or tax advice.

Notice details

Notice code
CP3219A
Category
Underreporter / income matching
Severity tier
Tier 4 — Escalation warranted. The notice involves collection enforcement, appeals rights, or significant penalty exposure.
Governing law
§6212; §6213 (Internal Revenue Code sections)
Statutory response window
90-day window — always confirm the exact deadline against the date printed on your notice.
Escalation flag
This notice carries a forfeitable right, a hard statutory deadline, or criminal-preparer risk. It is flagged for escalation in the TaxRiskOS workflow.
Source
IRS.gov — Understanding Your IRS Notice

What the IRS says to do

Read the notice carefully. The amounts due on the enclosed Form 5564, Notice of Deficiency – Waiver, may not match your prior notice amount due. This is because you can't challenge all items in U.S. Tax Court. Reply to the notice by the date listed.

This is the IRS’s own guidance reproduced from the IRS notice page. It describes the IRS’s process — it is not legal or tax advice from TaxRiskOS.

Governing IRS procedure (Internal Revenue Manual)

The IRS’s own internal procedures for handling this notice type are documented in the Internal Revenue Manual:

Reference to published IRS procedure. General information — not legal or tax advice.

Official IRS reference

Read the official notice page on IRS.gov: https://www.irs.gov/individuals/understanding-your-cp3219a-notice

Related tools

TaxRiskOS is workflow software for practitioners — it captures the notice, computes the deadline, surfaces the escalation tier, and builds a document checklist. It documents process; it does not give advice or draft responses.