IRS Notice LTR3219: Statutory Notice of Deficiency
A formal notice of proposed tax increase with the right to petition the Tax Court.
- Response deadline
- 90 days from the letter date (150 if outside the U.S.)
- Category
- Appeals & Collection Due Process
- Severity
- Critical
What does an IRS LTR3219 notice mean?
A Letter 3219 is a Statutory Notice of Deficiency that formally proposes an increase in your tax and explains the basis for it. Like the 692, it triggers your right to petition the U.S. Tax Court and starts a strict 90-day clock (150 days if you are outside the country) during which you can contest the deficiency without first paying it.
Why did you receive a LTR3219?
Unresolved proposed adjustments — from an underreporter notice or an examination — led the IRS to issue this final, appealable determination.
How to respond to a LTR3219 notice
If you disagree, file a Tax Court petition before the deadline printed on the notice; missing it forfeits the pre-payment appeal right. If you agree, sign the enclosed waiver and pay or arrange payment. Because this is a legal proceeding with firm deadlines, professional representation is highly recommended.
What happens if you ignore it?
The IRS assesses the deficiency after the deadline and proceeds to collection. You would then have to pay in full and pursue a refund claim to dispute the amount.
Common resolutions
- Petition the Tax Court
- Agree and pay
- Seek professional representation
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For informational purposes only. Not legal, tax, or medical advice.