The Notice of Deficiency IRS Letters 3219 and 531 (also referred to as 90-Day Letters), are a taxpayer’s legal notice that the IRS is proposing a deficiency (balance due). These letters provide taxpayers with information about their right to challenge proposed IRS adjustments in the United States Tax Court by filing a petition within 90 days of the date of their notice (150 days if the notice is addressed to a person outside the United States).
If the IRS is proposing to adjust the amount of tax you owe, you will typically be sent a statutory notice of deficiency informing you of the proposed change. IRS Letter 3219 is sent to taxpayers whose IRS audit was conducted by mail, while IRS Letter 531 is issued to taxpayers whose audits were conducted in person. Because this notice provides you with the right to challenge the proposed adjustment in the Tax Court without first paying the proposed adjustment, the statutory notice of deficiency is often considered “your ticket to the Tax Court.”
The IRS is required to send a statutory notice of deficiency to a taxpayer’s last known address by certified mail. The last known address is generally the address that appears on your most recently filed and properly processed tax return unless the IRS is given clear and concise notification of a different address.
The notice of deficiency must describe the basis for, and identify the amounts (if any) of, tax due, interest, and penalties.