Receiving IRS Letter 3219, also known as a Notice of Deficiency or 90‑Day Letter, is one of the most serious tax notices a taxpayer can receive. It means the IRS has determined that you owe additional tax and is giving you the right to challenge that determination before the tax is officially assessed.

👉See more videos on our channel about LITC Education and how CPA Clinics can help.

 
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🚨 What Letter 3219 Means

  • The IRS proposes additional tax liability based on its review of your return or other information.
  • You have 90 days (150 days if you are outside the U.S.) to file a petition with the United States Tax Court if you disagree.
  • If you do not file within the deadline, the IRS will assess the tax and begin collection actions.
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⚖️ Your Rights Under a Notice of Deficiency

  • You can petition the Tax Court to dispute the IRS’s determination before paying the tax.
  • You may present evidence, documentation, and arguments to support your position.
  • Filing a petition stops the IRS from assessing or collecting the proposed tax until the case is resolved.

⚠️ Common Complications

  • Missed Deadlines: If you fail to file within 90 days, you lose the right to challenge in Tax Court.
  • Incomplete Documentation: Many petitions fail because taxpayers don’t provide sufficient evidence.
  • Language Barriers: ESL taxpayers often struggle to understand the notice and their rights.
  • Escalation: If ignored, the IRS will assess the tax, add penalties and interest, and pursue collection actions (liens, levies, garnishments).

🛡️ How CPA Clinics (LITC) Helps

The Low Income Taxpayer Clinic (LITC) at CPA Clinics provides free or low‑cost representation for qualifying taxpayers. If you receive Letter 3219:

  • We explain the notice in plain language.
  • We help you decide whether to file a Tax Court petition.
  • We prepare and file the petition within the 90‑day deadline.
  • We represent you in Tax Court if your case qualifies.
  • We educate ESL taxpayers about their rights and responsibilities.

📖 Commonly Asked Questions

Q1: What happens if I ignore Letter 3219? 👉 The IRS will assess the tax, add penalties and interest, and begin collection actions.

Q2: Do I have to pay before filing a Tax Court petition? 👉 No. Filing a petition allows you to dispute the tax before paying.

Q3: Can I negotiate with the IRS instead of going to Tax Court? 👉 Yes. Options include settlement discussions or alternative dispute resolution. CPA Clinics can guide you.

Q4: Do I qualify for LITC help? 👉 If your income is within IRS guidelines (≤250% of the federal poverty level) or you speak English as a second language, you may qualify for free representation.

Q5: How long does a Tax Court case take? 👉 It varies, but filing within the deadline immediately stops IRS assessment until the case is resolved.

Contact Us – We’re Here to Help

If you’ve received IRS Letter 3219 (Notice of Deficiency), time is critical. You have 90 days to act.

📞 Phone: (516) 464‑7444
📧 Email: info@cpaclinics.com
🌐 Website: www.cpaclinics.com
📍 Locations: Bronx, Manhattan, Hempstead, Hicksville