Understanding IRS Form 5564: Your Rights and Risks
IRS Form 5564 does not arrive in a vacuum. It is an enclosure with a CP3219A notice, also known as a Statutory Notice of Deficiency (SNOD) or a "90-day letter." The IRS issues a CP3219A notice when it determines that there is a deficiency in a taxpayer's income tax, estate tax, gift tax, or certain excise taxes. A deficiency is the amount by which the tax imposed by the IRS exceeds the amount of tax shown on the taxpayer's return. The CP3219A notice is a critical legal doc
Howard Richardson
3 days ago4 min read






