What is the IRS collection statute of limitations? The IRS collection statute expiration date or “CSED” is the last day the IRS has to collect on an assessed tax debt (and associated penalties and interest).
The CSED is 10 years from the date of assessment. For example, the CSED a 4/15/2019 filer for a 2018 return in which the tax is assessed on 6/3/2019 is 6/3/2029.
Each tax year has its own CSED because each tax year is a separate assessment. A taxpayer can have multiple CSEDs during a year if they have multiple assessments. For example, the taxpayer may file and assess tax on 6/3/2019 and then get audited for the same year. The IRS audit adjustment would be assessed after the 6/3/2019 assessment date and create a second CSED for the amount of the audit assessment.
CSED can be extended by taxpayer actions. Here are some common ways taxpayers can extend the CSED:
| Action | CSED extended time |
| Bankruptcy | Bankruptcy period + 6 months |
| Collection Due Process Appeal Request | Appeals request through decision period (not less than 90 days) |
| Offer in Compromise | Offer review/appeal period + 30 days (Offers after 3/9/2002) |
| Installment agreements | ·Time proposed installment agreement is pending
·30 days after rejection of an installment agreement ·30 days after a termination of an installment agreement ·Any appeal of the termination or rejection of an installment agreement |
| Innocent spouse | The collection period is suspended from the filing of the claim until the earlier of the date a waiver is filed, or until the expiration of the 90-day period for petitioning the Tax Court, or if a Tax Court petition is filed, when the Tax Court decision becomes final, plus, in each instance, 60 days |
| Taxpayer living outside US | Period outside of U.S. (if absence > 6 months) |
| Combat zone | Period while in combat zone plus 180 days |
| Taxpayer Assistance Order | Period receiving assistance from Taxpayer Advocate Office (Note: the IRS rarely “inputs” this extension) |
The IRS does not provide taxpayers their CSED – taxpayers need to ask the IRS for their CSED (call the IRS accounts hotline or get a tax professional to cut through the red tape and get the answer quickly). Also, the IRS does not provide a document that shows how the CSED was computed. Taxpayers can attempt to estimate their CSED date using IRS account transcripts. The transcript will contain these codes that would indicate the CSED was extended:
| Account Transcript Transaction Code | Description |
|---|---|
| TC 480 | Offer in Compromise Pending |
| TC 488 | Installment and/or Manual Billing |
| TC 500 | Military Deferment |
| TC 520 cc 76-81 |
IRS Litigation Instituted |
| TC 520 cc 60-67, 83, 85-89 |
Bankruptcy |
| TC 550 | Waiver Extension of Date Collection Statute Expires (extends the CSED to date input) |
| TC 971 Action Code 043 |
Pending Installment Agreement |
| TC 971 Action Code 163 |
Terminated Installment Agreement |
Taxpayers who question their CSED dates have good reason to suspect an error. In a 2013 Treasury Inspector General for Tax Administration study, TIGTA found that 39% of sampled accounts had incorrect CSED calculations. When TIGTA studied the CSED computation accuracy issue again in 2017, they found similar errors. In 2018, the Taxpayer Advocate blog said the problem was worse than expected, with no relief in sight.
If you want to get the IRS’ calculation of the collection statute of limitations, you can ask the IRS. You will need to get a more detailed IRS transcript- called a TXMODA (IRS jargon for the name of a detailed account transcript). If the IRS resists providing this information, submit a Freedom of Information Act request. Unless the CSED is debate, a transcript review will give you the information you need to evaluate whether the IRS has the CSED correct or further in-depth analysis is needed.
Remember, the CSED is important. Once the CSED expires, the IRS writes off the debt. Account transcripts show a transaction code 608 with the balance amount that was written off due to the collection statute expiration.