IRS Levies and the Collection Statute Expiration Date (CSED)

Marc Boulanger • August 25, 2025
A collection statute expiration date stamp is sitting on top of a stack of papers

The IRS Can’t Collect Taxes Forever—Here’s What You Need to Know


When the IRS levies your wages, bank accounts, or property, it feels like they have unlimited power—but that’s not entirely true.


The IRS only has 10 years to collect on most federal tax debts. This limit is known as the IRS 10-year collection statute (Collection Statute Expiration Date or CSED)—and it plays a huge role in how long a levy or lien can legally stay in place.


In this blog, we explain how levies interact with the 10-year collection statute, how the IRS tries to pause or extend that clock, and how to use the CSED to your advantage.


What Is the CSED?


The Collection Statute Expiration Date is the last day the IRS can legally collect a tax debt. It’s usually:

10 years from the date the tax was assessed

After that, the IRS must stop all collection activity—including levies—and remove any liens still on record.


If you’re weighing IRS levy vs lien differences, remember: a levy takes your money or property directly, while a lien is simply a legal claim against your assets. Both are subject to the same CSED rules.


How IRS Levies Work Within the CSED Window


If your tax debt is still within the 10-year window:


  • The IRS can issue a levy at any time
  • They do not need a court order
  • The levy can remain active until the CSED expires, unless released sooner


Once the CSED passes:


  1. The IRS must release all active levies
  2. You are no longer legally liable for the balance


For example, if you’re dealing with an IRS bank account levy in California, that levy will remain enforceable only until your CSED date runs out—unless you take action to stop it sooner.


But Here’s the Catch: The Clock Can Stop or Pause


The CSED doesn’t always run uninterrupted. It gets paused or extended (called “tolling”) during:



Each tolling event adds time to the CSED clock—sometimes months or years. If you’re considering settling tax debt with an Offer in Compromise, keep in mind that the review period pauses the statute temporarily.


How to Find Out When the CSED Expires


To determine your expiration date, you’ll need to:


  1. Pull your IRS account transcript
  2. Look at the date the tax was assessed (not the filing date)
  3. Review the timeline for any tolling events
  4. Calculate the adjusted expiration date
Related: IRS Tax Transcripts – Why They Matter

What Happens If the IRS Levies After the CSED?


That’s illegal.


If the IRS collects money after the CSED has passed, you may be entitled to:


  • A refund of the levied funds
  • Interest compensation
  • Potential damages under IRC §7433 (if your rights were violated)


This is why knowing can you stop an IRS levy after it starts is so important—especially when the CSED deadline is near.


Strategic Use of the CSED to Stop or Prevent Levies


Knowing your CSED helps you:



We Help Orange County Taxpayers Stop Levies and Time Out the Clock


At Boulanger CPA and Consulting PC, we:


  • Analyze your IRS transcripts to calculate CSED dates
  • Stop active levies and protect your accounts
  • Negotiate solutions that avoid resetting the clock
  • Get levied funds refunded if enforcement was illegal


We also encourage taxpayers to learn more in Defend What’s Yours—because the best defense against the IRS is knowing your rights and planning ahead.


Call (657) 218-5700 or book your CSED review at www.orangecounty.cpa


Frequently Asked Questions

What is the Collection Statute Expiration Date (CSED)?

The CSED is the date the IRS’s 10-year time limit to collect a tax debt expires. After this date, the IRS can no longer enforce collection, including levies.

Does the IRS always stop collections once the CSED passes?

Yes. Once the statute expires, the IRS must release any liens or levies and can no longer pursue enforced collection on that debt.

Can the CSED be extended?

Yes. Certain actions—like filing bankruptcy, submitting an Offer in Compromise, or leaving the country for an extended period—can pause or extend the statute.

What happens if the IRS levies my account right before the CSED expires?

If funds are levied before the CSED expires, the IRS may keep them. Once the CSED passes, the IRS must stop future levies but doesn’t return amounts already seized.

How do I know when my CSED date is?

You can determine the CSED from IRS account transcripts. Each tax year has its own statute date based on when the tax was assessed.

Can negotiating with the IRS extend the CSED?

Yes. Requests for installment agreements, OICs, or appeals can extend the collection statute. It’s important to weigh options carefully before filing.

Do California tax debts have a statute of limitations too?

Yes. The Franchise Tax Board (FTB) has its own statute of limitations, which is generally longer than the IRS’s 10-year rule and may be extended under certain conditions.

Should I get professional help if my debt is near the CSED?

Yes. Professional review ensures you don’t accidentally extend the statute and helps you plan for resolution while protecting your rights.

📣 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.


He is the author of Defend What’s Yours: A California Taxpayer’s Guide to Beating the IRS and FTB at Their Own Game, available now on Amazon. The book offers a step-by-step plan for resolving IRS and FTB tax debt without losing your business, your home, or your peace of mind.


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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