IRS NOTICE REFERENCE

Letter 3219 Notice of Deficiency

The Letter 3219 is the IRS ’s way of notifying you they are proposing to make changes to the return you filed and those changes will result in additional taxes being owed. Generally, this Letter is sent to a taxpayer who…

General information only. Not legal or tax advice.

Notice details

Notice code
Letter 3219
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 Taxpayer Advocate Service

What this notice is

The Letter 3219 is the IRS ’s way of notifying you they are proposing to make changes to the return you filed and those changes will result in additional taxes being owed. Generally, this Letter is sent to a taxpayer whose audit w as conducted by mail and is called a statutory notice of deficiency. The IRS is required to send any statutory notice of deficiency to a taxpayer’s last known address by certified or registered mail. The last known address is generally the address which appears on your most recently filed and properly processed federal tax return unless the IRS is given clear and concise notification of a different address. Form 8822 , Change of Address, can be used by taxpayers to

Source: IRS Taxpayer Advocate Service. Reproduced for reference. General information — not legal or tax advice.

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.taxpayeradvocate.irs.gov/notices/letter-3219/

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.