IRS NOTICE REFERENCE
Understanding Your Letter 3219B
This Statutory Notice of Deficiency notifies you of our intent to assess a tax deficiency and of your right to petition the U.S. Tax Court to dispute the proposed adjustments. We made these adjustments because we receive…
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 3219B
- Category
- Underreporter / income matching
- Severity tier
- Tier 4 — Escalation warranted. The notice involves collection enforcement, appeals rights, or significant penalty exposure.
- Governing law
- §6201; §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 this notice is
This Statutory Notice of Deficiency notifies you of our intent to assess a tax deficiency and of your right to petition the U.S. Tax Court to dispute the proposed adjustments. We made these adjustments because we received information from third parties that doesn’t match the information you reported on your return.
Source: IRS.gov. Reproduced for reference. General information — not legal or tax advice.
What the IRS says to do
Review this notice and compare our changes to the information on your tax return. The amounts shown as due on the notice may not match your previous notice because you cannot challenge all items in tax court. If you agree with the changes, sign and return Form 4089, Notice of Deficiency - Waiver, to limit additional interest charges. If you don't send a payment with Form 4089, we’ll send a bill for the amount due with any interest and applicable penalties. If you don’t agree with the changes and have additional information, immediately mail it to us at the address listed on the notice. Attach this notice to your correspondence to help us identify your case. Keep a copy for your records. This won’t extend your deadline to file a petition with the U.S. Tax Court. In addition, if you don’t agree with the changes, you have the right to challenge the increase in tax by filing a petition with the U.S. Tax Court no later than the date listed on the notice. The Court can’t consider your case if you file the petition late. You can download a fillable petition form and get information about filing at U.S. Tax Court . The Tax Court encourages petitioners to electronically file petitions. You can eFile your completed petition by following instructions and user guides available on the Tax Court’s DAWSON system website. You will need to register for a DAWSON account to do so. Or you may send the completed petition to: Clerk of the U.S. Tax Court 400 Second Street, NW Washington, DC 20217
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:
- IRM 4.19.3 — 4.19.3 IMF Automated Underreporter Program
- IRM 4.19.2 — 4.19.2 IMF Automated Underreporter (AUR) Control
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-letter-3219b
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.
Check this notice’s deadline (free tool)