Statute of Limitations on IRS Collections

Under IRC §6502, the IRS has 10 years from the date of assessment to collect a tax debt. After that date — the Collection Statute Expiration Date — the debt goes to zero. The IRS cannot collect a single dollar after the CSED passes.

This is one of the most powerful provisions in the tax code, and most taxpayers have no idea it exists.

When the Clock Starts

The CSED clock starts on the assessment date, shown as TC 150 on your IRS account transcript for a filed return. For audit adjustments, TC 290 or TC 300 starts a separate clock for the additional assessment. Each assessment has its own CSED. You can have multiple CSEDs running simultaneously across different tax years.

Tolling Events — When the Clock Stops

Certain actions stop the 10-year clock. An OIC tolls the statute while pending plus 30 days. A CDP hearing tolls during the entire pendency. Bankruptcy tolls plus six months after discharge. An installment agreement request tolls while pending plus 30 days after rejection. Living outside the U.S. for six or more continuous months tolls under IRC §6503(c).

This is why strategy matters. Filing an OIC when you have 18 months left on the CSED is often worse than simply waiting in CNC status. The OIC stops the clock. CNC does not.

Form 900 Waivers

The IRS sometimes asks taxpayers to sign Form 900, which extends the CSED by written agreement. Never sign one without consulting a tax attorney. Once signed, you have given the IRS more time to collect. We calculate CSEDs and build strategies around them.

Tax attorney Darrin Mish has spent 32 years getting taxpayers out of IRS trouble. Free consultation — no obligation.