01. International Tax

We provide tailored solutions to complex global businesses doing business in the U.S. Small or multinational, we guide clients through the maze of complex U.S. international tax rules.

02. Offshore Tax Compliance

We assist clients with specialized counsel to fix noncompliance with international tax reporting and penalties. FBAR, forms 8938, 8621, 3520, 926, 5471 and 5472 are among the most common forms that we solve through compliance programs such as streamlined procedures, Voluntary Disclosure Program or the Delinquent International Information Return Submission Procedures (DIIR).

03. Small Business Tax Planning

We assist small and medium businesses with efficient tax structuring to improve efficiencies. Proper tax election, s-corp elections and partnership planning are some of the main solutions offered.

04. Controversy Tax

We guide and represent clients before the IRS including examinations and appeals, as well as represent clients in Tax Court or Federal Courts.

05. Tax Debt Resolution

We help clients to face harsh collection activities, including liens, levies and obtaining a collection alternative such as an offer in compromise, installment payment plans, among others.

06. IRS Criminal Investigations

Our Firm provides representation before IRS Criminal Investigation Division, including Malta Pension Plans and summons.

07. High Net Worth & Family Offices

Assistance with estate planning for select clients and those with cross-border operations, planning for inheritance taxes, and gift taxes in the USA.

08. Start-Ups & Business Tax

No matter how small the idea, we assist clients with the best tax planning and alternatives for their business.

09. Crypto Tax

Our Firm provides tax planning and tax advice on crypto assets and crypto events, including mining, forks, rewards, and disposition/exchange of crypto.

10. BOI Report- Corporate Transparency Act

We assist business owners, CPA and tax preparation firms to file the Beneficial Ownership Information (BOI) report with the FinCEN.

IRS Letter 3219: What It Is and What You Should Do

IRS Notices

08.20.2025

Receiving a notice from the IRS can be unsettling—especially when it involves a proposed tax deficiency. If you’ve received IRS Letter 3219, also known as the Notice of Deficiency, it’s critical that you understand what it means and take action promptly. This is a formal legal notice that grants you a short window to either resolve the issue or exercise your right to dispute the IRS’s position in court—before the government begins enforcement.

What Is IRS Letter 3219?

IRS Letter 3219 is a statutory notice of deficiency. It is sent after the IRS has determined that you owe additional taxes—usually following an audit or failure to file a return. The IRS uses information from third parties (such as employers, banks, or brokers) to calculate your tax liability, and if you do not respond to previous notices or disagree with their findings, Letter 3219 is issued.

This letter is the IRS’s final determination before assessing the additional tax. It also serves as your legal notice and opportunity to dispute the adjustment without first paying the amount due.

What Does Letter 3219 Include?

The notice outlines:

    • The proposed tax increase and an explanation of the adjustments made.
    • A breakdown of the amounts related to income, deductions, or credits that were changed.
    • A Form 5564 (Notice of Deficiency – Waiver) to sign if you agree with the changes.
    • Information on how to file a petition with the U.S. Tax Court if you disagree.

This letter is not a bill, but it is a legal trigger for the IRS to assess the tax if you do not respond within the time allowed.

When Do I Take Action?

From the date printed on the letter, you have 90 calendar days (or 150 days if you are outside the U.S.) to file a petition with the U.S. Tax Court. This is a strict legal deadline. The IRS will not grant extensions, and if you miss it, you will lose the right to dispute the tax deficiency in court.

Filing a petition suspends collection efforts until the case is resolved.

What Are My Options?

You have two options:

    1. If you agree with the IRS: Sign and return Form 5564. You can then pay the balance voluntarily or wait for the IRS to issue a bill.
    2. If you disagree with the IRS: File a petition in U.S. Tax Court before the deadline. This allows you to challenge the proposed liability without prepayment. For disputes under $50,000 per tax year, you may qualify for the simplified “Small Tax Case” process.

 

Be aware: Calling or mailing documents to the IRS does not preserve your rights. Only filing a formal petition will stop the IRS from proceeding.

Relevance for Taxpayers

For individuals and businesses alike, Letter 3219 can have serious financial and legal consequences. Ignoring it can lead to IRS assessments, collection actions, levies, liens, and garnishments. If you disagree with the IRS’s findings, this is your one chance to contest them before the agency begins collection.

Timely, informed action is not just recommended—it’s essential.

We Can Help!  

At JH Tax Law, we provide strategic legal representation for taxpayers facing IRS disputes, including notices of deficiency. You don’t have to face the IRS alone. Let us protect your rights and guide you through every step of the process.

Contact our office today for a confidential consultation and assert your position with clarity and legal authority.