The IRS 10-Year Collection Statute – CSED Rules Explained

Marc Boulanger • May 16, 2025
A folder with a label that says 10 year collection statute csed rules

Yes, IRS Debt Expires—Here’s How the Clock Works


One of the most misunderstood aspects of IRS tax debt is this: it doesn’t last forever. The IRS has a 10-year window to collect most tax debts, known as the Collection Statute Expiration Date (CSED). After this period expires, the IRS generally cannot legally collect the debt.


However, calculating the actual expiration date isn’t always straightforward—and many taxpayers unknowingly restart the clock by taking certain actions.


In this post, we explain how the 10-year IRS collection statute works, how to estimate your CSED, and what you can do if you're approaching expiration.


What Is the IRS Collection Statute of Limitations?


The Collection Statute Expiration Date (CSED) is the date by which the IRS must collect your assessed tax liability. In most cases, that window is:

10 years from the date the tax was assessed

Once the CSED passes, the IRS can no longer legally enforce collection—no garnishments, no levies, no liens.

Related: Tax Transcripts – Why They Matter

When Does the 10-Year Clock Start?


The 10-year collection period begins on the date the IRS assesses the tax—not when you file your return.


Key triggering events:

  • Timely filed return: Assessment usually happens shortly after processing
  • Audit or amended return: Assessment date resets to when changes are finalized
  • Substitute for Return (SFR): IRS files on your behalf, assessment date follows


You can find assessment dates on your IRS transcripts or by working with a tax professional.


What Can Pause or Extend the CSED?


Certain actions pause the 10-year clock, known as "tolling" the statute. The time paused is added to your original 10-year expiration.


These include:

Action Tolling Effect
Filing an Offer in Compromise – How to Settle for Less Than You Owe Pauses clock during review + 30 days
Filing for bankruptcy Tolling during bankruptcy + 6 months
Requesting a Collection Due Process hearing Pauses until decision issued
Filing an Innocent Spouse claim Pauses while under consideration
Living outside the U.S. for 6+ months Tolling may apply during absence
Requesting an Installment Agreement Pauses clock while under review


Why This Matters: Planning Your Strategy


Understanding your CSED is a powerful tool when resolving back taxes. If your IRS debt is close to expiration, you may benefit from strategies that:


Can the IRS Restart the Clock?


No—but they can extend it if you allow it.


Be cautious about:

  • Signing Form 900 or any waiver that extends the statute
  • Filing unnecessary resolutions that pause the statute close to expiration


Never agree to toll or extend the CSED unless there’s a clear strategic benefit.


How Do You Know When Your CSED Hits?


To confirm expiration dates:

  1. Pull your Tax Transcripts – Why They Matter
  2. Track assessment dates and tolling periods
  3. Calculate projected CSED per tax year


Our office can run this full analysis for you to ensure you're not being pursued illegally.


We Help Orange County Taxpayers Navigate the IRS Statute of Limitations


At Boulanger CPA and Consulting PC, we:

  • Analyze your transcripts and CSED timeline
  • Help you avoid tolling mistakes
  • Defend against IRS collections near expiration
  • Guide you through strategic use of hardship status or installment plans


Call (657) 218-5700 or book online at www.orangecounty.cpa

Frequently Asked Questions

  • Can the IRS collect after 10 years?

    Not unless the Collection Statute was extended through tolling or voluntary waiver.

  • What tolls the CSED?

    Filing an Offer in Compromise, bankruptcy, CDP requests, and other actions can pause the 10-year clock.

  • How can I check my CSED?

    Review your IRS transcripts or work with a tax professional to calculate it correctly.

  • Is it better to wait out the statute or resolve the debt?

    It depends—if you're near expiration, a strategic pause may work. But every case is different.




📣 About the Author


Marc Boulanger, CPA is the founder of Boulanger CPA and Consulting PC, a boutique tax resolution firm based in Orange County, California and trusted by high-income individuals and business owners across Southern California.


With over a decade of experience resolving high-stakes IRS and State tax matters, Marc brings strategic insight to complex cases involving wage garnishments, bank levies, unfiled returns, and six-figure tax debts. He is known for helping clients reduce or eliminate tax liabilities through expertly negotiated settlements and compliance plans.


Marc is a Certified Public Accountant licensed in California and Oklahoma and holds the designation of Certified Tax Representation Consultant. He is a member of the American Society of Tax Problem Solvers (ASTPS) — the national organization founded by the educators and practitioners who have trained thousands of CPAs, EAs, and tax attorneys in IRS representation strategy.


Every case is handled with discretion, proven methodology, and direct CPA-led representation — not call center scripts.


📍 Learn more at www.orangecounty.cpa or call (657) 218-5700.


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