Statutory Notice of Deficiency (Letter 3219B)

Why you might get this

• A bank, business, or other payer reported income to the IRS that doesn't match what you reported on your return (Form 1120 for corporations or Form 1041 for estates and trusts).
• The IRS reviewed the mismatch and decided to propose additional tax, which is called a 'deficiency.'
• This letter is the official 'Statutory Notice of Deficiency' — a formal step that gives you the legal right to take the matter to the U.S. Tax Court.
• Income may have been reported under your name or taxpayer ID that actually belonged to someone else.

The deadline

This is not a bill yet — it's a formal notice that protects your right to dispute the proposed tax in the U.S. Tax Court. To keep that right, you must file a petition with the Tax Court by the exact date printed on your notice. This deadline cannot be extended, and sending more information to the IRS does not push it back. If you file a petition late, the court cannot hear your case.

This notice doesn't carry a fixed response deadline, but it still deserves attention — see what to do below.

What to do

1. Read the notice and compare the IRS's changes line by line with what you reported on your return.
2. If you agree, sign and return Form 4089 (Notice of Deficiency - Waiver) to stop extra interest from building up. You can include payment to reduce interest further.
3. If you disagree and have documents that support your position, mail them to the address on the notice right away, and attach this notice so they can find your case.
4. If you want to preserve your right to challenge the tax, file a petition with the U.S. Tax Court by the date printed on the notice — you can eFile through the Tax Court's DAWSON system or mail it to the Clerk of the U.S. Tax Court in Washington, DC.
5. If the income belonged to someone else, send the IRS that person's or business's name, address, and taxpayer ID, and ask the payer to correct their records.
6. Check your other returns to make sure the same mistake isn't repeated, and keep a copy of the notice for your records.

What happens if you ignore it

If you don't respond or file a Tax Court petition by the date on the notice, the IRS will assume the proposed changes are correct and formally assess the extra tax. After that, they'll send a bill for the amount due plus interest and any penalties.

The Tax Court deadline is strict and cannot be extended, so if you plan to dispute the tax, consider talking to a tax professional or tax attorney quickly. If you can't pay the full amount, you can ask about a payment plan (installment agreement) using Form 433-D.

What Letter 3219B means

Letter 3219B is a Statutory Notice of Deficiency — the IRS's formal way of telling you it plans to charge more tax and explaining your right to fight that decision in the U.S. Tax Court. The IRS usually sends it after comparing your return with income records from banks, businesses, and other payers and finding amounts that don't match.

This letter is not a bill. It's a legal step that opens the door to challenge the proposed tax. If you agree, you can sign and return Form 4089 to limit added interest. If you disagree, you can mail supporting documents to the IRS, or file a petition with the U.S. Tax Court to formally dispute the change.

The most important thing to know: there's a firm date printed on your notice for filing a Tax Court petition, and that date can't be extended. Sending extra information to the IRS won't push it back, so act early.

If the income wasn't yours, gather the real recipient's details and ask the payer to fix their records. Keep a copy of everything.

Solace can keep an eye on your IRS account so you're not caught off guard by what happens next.