IRS NOTICE REFERENCE

Letter 3219-C

The IRS determined there’s a deficiency in your income tax. This letter is your Notice of Deficiency, as required by law. Deficiency means that the IRS has calculated your tax amount to be higher than was reported on you…

General information only. Not legal or tax advice.

Notice details

Notice code
Letter 3219-C
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 IRS determined there’s a deficiency in your income tax. This letter is your Notice of Deficiency, as required by law. Deficiency means that the IRS has calculated your tax amount to be higher than was reported on your tax return. Letter 3219C, Statutory Notice of Deficiency (also referred to as 90-Day Letter), is your legal notice that the IRS is proposing. This letter provides you with information about your right to challenge the proposed IRS adjustments in the United States Tax Court by filing a petition within 90 days of the date of your notice (150 days if you reside outside the United States).

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

What the IRS says to do

Read the notice carefully You should determine if you agree with the proposed changes or wish to file a petition with the Tax Court to dispute the adjustments made by the IRS. If you agree with the changes, sign and return the Consent to Assessment and Collection Waiver Statement, at the end of the letter. The IRS requires both spouses signatures if you were married filing jointly for that return.

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

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.