What CP 3219A is
The notice of deficiency, with Form 5564 waiver, issued when a CP 2000 is not resolved. The payee has 90 days (150 outside the United States) to petition the Tax Court, and "statutory and IRS employees can't extend it" (IRM 4.19.3.2.1.1(4), Oct. 2, 2024). After the 90 or 150 days "plus 15 additional days, the tax deficiency is assessed by default" (IRM 4.19.3.23.10(6) Note, Oct. 10, 2025).
The deadline
90 days (150 outside the U.S.) to petition; no extension. Default assessment at day 105.
What to do
A payer's corrected return still matters: a decrease after the statutory notice is made by recomputed CP 2000 if time remains (IRM 4.19.3.23.8.1(9)), and after assessment through reconsideration, where "Corrected document" is a listed ground (Exhibit 4.19.3-13). Send the payee the corrected form and a signed explanation at once.
What a notice of deficiency changes
A CP2000 is a proposal; the IRS cannot assess the tax on it without the taxpayer's agreement. A notice of deficiency is the legal step that lets it assess without agreement. CP 3219A is the notice of deficiency issued in underreporter cases when the CP2000 went unanswered or the response did not resolve the discrepancy. It restates the proposed tax, encloses Form 5564 for a taxpayer who agrees, and starts a 90-day clock (150 days for an address outside the United States) during which the taxpayer may file a petition with the United States Tax Court. The clock is statutory. No one at the IRS can extend it, a pending correspondence case does not pause it, and when it runs out the deficiency is assessed by default. A payee who disputes the figures and cannot get them fixed in time files the petition to preserve the right to dispute them; many such cases are then settled with the IRS before any hearing.
What a payer can still do
A corrected information return still changes the outcome, but the route depends on timing. While days remain on the 90, the unit can recompute the case and issue a revised CP2000 that reduces or removes the deficiency, so a payer who learns at this stage that its 1099 was wrong should file the correction and send the payee a copy with a signed statement the same week, by fax if the payee has the unit's number. After the 90 days and the default assessment, the payee's remedy is audit reconsideration, for which a corrected document from the payer is a recognized ground; the correction and statement are the core of that request. If the payee asks for a statement rather than a correction because the return was right, give them one that explains the figure, and let them decide how to use it. The correct-1099 guide covers the explanation, the corrections page covers the filing, and the Letter 2625-C page covers the case where the IRS writes to you directly.
Questions about CP 3219A
Who receives CP 3219A?
Payee. The notice of deficiency, with Form 5564 waiver, issued when a CP 2000 is not resolved.
What is the deadline on CP 3219A?
90 days (150 outside the U.S.) to petition; no extension. Default assessment at day 105.
What should I do when CP 3219A arrives?
A payer's corrected return still matters: a decrease after the statutory notice is made by recomputed CP 2000 if time remains (IRM 4.19.3.23.8.1(9)), and after assessment through reconsideration, where "Corrected document" is a listed ground (Exhibit 4.19.3-13). Send the payee the corrected form and a signed explanation at once.
Is CP 3219A about my own income tax?
No. This decoder covers information reporting and withholding: the notices a payer, filer or payee sees because of Forms 1099, W-2, 945 and the TINs on them. Individual income-tax notices follow a different track.
Have a different notice? The IRS notice decoder lists all 77 in the order they tend to arrive.