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Gary Bode, CPA is a Master's Degreed, nation wide accountant offering tax and business services. Member of AICPA and NCACPA. Our virtual office provides excellent service to long distance and international clients. Call (910) 399-2705 for a free phone consult.

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"Gary does a great job on finding expenses for my rental properties. His virtual office makes tax time a lot more convenient. I added him to Angie's list!"—Molly Baxter

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IRS Letter Number 3219 CPA explains the 90 Day Letter | IRS tax notice | Notice of Deficiency

IRS Letter Number 3219 CPA discusses the IRS 90 Day Letter, the Notice of Defiency.

The IRS 90 Day Letter deserves immediate attention if you don’t agree with the IRS. (910) 399-2705.

IRS tax notices command attention. But Letter Number 3219 raises the most concern with CPAs. Why?

  • The IRS claims you owe taxes.
  • You have limited options.
  • The timeline is less than 90 days.

Receiving Letter Number 3219 probably means you don’t have a CPA. Most of my blogs suggest self-sufficiency in IRS matters when appropriate, but you need professional CPA help now.

“The IRS has now lost patience with you.”
– Gary Bode, IRS tax notice CPA

Your Issues

IRS Letter Number 3219 “clearly” states the IRS perspective on why you owe tax. But it takes some experience to understand what they’re actually saying. Make sure your CPA understands your side of the story.

Can you fight the 90 day Letter?

Yes. If you disagree with Letter Number 3219, you can petition the US Tax Court. But it has to be within 90 days from the date of the Notice of Deficiency. After 90 days you’re stuck with the IRS figures even if they’re wrong. And they can be wrong. I wouldn’t just pay them without checking. Usually the IRS is generous with time lines. But not here. This is your last chance to fight. Get an immediate professional opinion or just pay them.

The Auditor

Once you petition the Tax Court, the auditor working the case has an incentive to work with your CPA. Why? The IRS has administration costs like any business. And the auditors are probably evaluated by how many cases they close. So just filing the petition can help.

The Appeals Officer and IRS Appeals Division

Tax Court is an expense for the IRS and your petition goes to an Appeals Officer who might have some leeway to negotiate a settlement to avoid a trial. If it can’t be settled in the appeals process, you go to Tax Court.

Who can Represent you for Letter Number 3219?

Yourself, but that’s not advisable. A CPA or Tax Attorney is your best bet.

I’m a CPA with a virtual office to represent you for IRS tax notices wherever you live. For a free phone consult call (910) 399-2705.

4 comments to IRS Letter Number 3219 CPA explains the 90 Day Letter | IRS tax notice | Notice of Deficiency

  • Tony Demory

    GARY MY NAME IS TONY.THE IRS SENT ME A 4464C FORM…I SENT THEM ALL THE INFOR…THEY ASK FOR…NOW 9 MONTHS LATER I STILL HAVE NOT GOTTEN MY TAXES…NOW THEY SAID THAT THEY ARE GOING TO SEND ME A 3219C FORM…I DON,T UNDERSTAND THIS IRS …THEY OLE ME MONEY…WHAT CAN BE DONE…THANKS…

  • Linda A

    I received a NOD from the IRS for unpaid income. The income was not filed on my tax return but on my husbands tax return. The management company put the rental income under the wrong SS# (not even mine or my husbands) but it had my address on there. Somehow the IRS still connected to my tax return. I filed submitted an appeal but that’s still pending. The date on the NOD will expire before I get the result of my appeal. Do I have a good case to file a petition or should I just pay the $3K. If I pay the $3k, would the IRS refund the money if the appeal goes my way? I just don’t want the the fees & interest to add on.

    • I would never advise paying the additional 3K without a fight. You and Hubby should go in person to the local IRS office. At the very least that will buy you time. If they can’t fix it immediately we’ll try a letter.

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