Understanding IRS Notice CP3219 or LTR 3219 and How an Enrolled Agent Can Help

Understanding IRS Notice CP3219 or LTR 3219 and How an Enrolled Agent Can Help

June 09, 20254 min read

IRS Notice CP3219 or LTR 3219, also known as a Statutory Notice of Deficiency, is one of the most serious communications a taxpayer can receive. It means the IRS has proposed changes to a tax return and intends to assess additional tax, usually because the taxpayer did not respond to a prior notice such as CP2000 or LTR 566. This notice gives the taxpayer 90 days (or 150 days if outside the United States) to respond before the IRS can assess the tax and begin collection. Receiving a CP3219 or LTR 3219 requires immediate attention, and an Enrolled Agent (EA) from Books, Taxes & More is critical to help manage the situation effectively and protect the taxpayer’s rights.  DO NOT TRY TO HANDLE THIS ALONE.

📌 Purpose of IRS CP3219 or LTR 3219

The primary purpose of CP3219 or LTR 3219 is to notify the taxpayer of the IRS’s intent to assess tax based on proposed changes and to provide an opportunity to dispute those changes before they become final. The notice is issued when earlier attempts to resolve a discrepancy have gone unanswered or unresolved.

This is a legal notice, also called a 90-Day Letter, and it is required before the IRS can assess additional tax without the taxpayer’s consent. It also serves as a formal invitation to file a petition with the U.S. Tax Court if the taxpayer disagrees with the proposed changes.  Filing a tax court petition can be done without a tax lawyer but should only be done in the simplest cases when the taxpayer is sophisticated enough to understand the process.

🧾 What CP3219 or LTR 3219 Includes

  • A summary of the proposed changes to the return

  • The reason for the changes, often related to unreported income or disallowed credits

  • The amount of additional tax, penalties, and interest

  • The deadline to respond or petition the Tax Court

  • Instructions on how to respond or contest the notice

Once the 90-day deadline passes, the IRS will assess the tax and begin the collection process, which could include liens or levies.

Options for Responding to CP3219 or LTR 3219

These steps should only be attempted in consultation with an Enrolled Agent.

1. Agree With the Proposed Changes

  • Sign the enclosed form and return it by the deadline

  • Submit payment in full or request a payment plan

2. Disagree With the Proposed Changes

  • File a petition with the U.S. Tax Court within 90 days of the notice date

  • The IRS cannot assess or collect the proposed amount during this period

  • Prepare documentation to support the case if filing a petition

3. Submit Missing Documentation
If the notice was sent because of missing responses to a CP2000 or audit notice, the taxpayer can often still submit supporting records. However, if the 90-day deadline is near, this should be done while simultaneously filing a Tax Court petition to preserve appeal rights.

Failing to act within the 90-day window results in the IRS automatically assessing the tax, which can limit options for contesting the amount later.

👨‍💼 How an Enrolled Agent from Books, Taxes & More Can Help

Steve Perry, Enrolled Agent is a federally licensed tax professional with the authority to represent taxpayers before the IRS in all matters, including audits, collections, and appeals. When a CP3219 or LTR 3219 notice is received, time is critical. Steve can:

  • Review the notice for accuracy and explain the proposed changes

  • Determine whether the IRS position is correct or based on errors

  • Help gather missing documentation to dispute the proposed changes

  • Advise on whether to file a petition with the Tax Court and assist with the process

  • Communicate with the IRS on the taxpayer’s behalf to resolve the issue

  • Explore payment options if the tax is valid but unaffordable

Having Steve Perry, EA from Books, Taxes & More involved provides peace of mind, ensures deadlines are met, and increases the likelihood of a fair outcome.

📣 Final Thoughts

IRS Notice CP3219 or LTR 3219 is serious and requires immediate action. It signals that the IRS intends to assess tax, and the taxpayer has a limited window to respond or take legal action. Ignoring the notice can lead to enforced collections and loss of appeal rights.

Steve Perry, Enrolled Agent is uniquely qualified to step in, evaluate the situation, and guide the taxpayer through the proper steps. Whether agreeing with the IRS, disputing the notice in Tax Court, or negotiating a resolution, an EA can ensure the process is handled accurately and professionally.

For anyone who receives CP3219 or LTR 3219, responding quickly and with the help of Books, Taxes & More is essential to protect their financial well-being and legal rights.

 

Steve Perry is a seasoned tax expert and Enrolled Agent licensed by the Department of the Treasury to represent taxpayers before the IRS. As the founder of Books, Taxes & More, LLC, Steve brings a no-nonsense, veteran-led approach to solving complex tax issues. With a background in military leadership, accounting, and financial services, he is fiercely committed to defending clients against aggressive IRS tactics and helping them preserve more of their hard-earned money. Whether it’s tax representation, planning, or preparation—Steve speaks IRS so you don’t have to.

Steve Perry

Steve Perry is a seasoned tax expert and Enrolled Agent licensed by the Department of the Treasury to represent taxpayers before the IRS. As the founder of Books, Taxes & More, LLC, Steve brings a no-nonsense, veteran-led approach to solving complex tax issues. With a background in military leadership, accounting, and financial services, he is fiercely committed to defending clients against aggressive IRS tactics and helping them preserve more of their hard-earned money. Whether it’s tax representation, planning, or preparation—Steve speaks IRS so you don’t have to.

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