IRS Levies and the Collection Statute Expiration Date (CSED)

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 Collection Statute Expiration Date (CSED)—and it plays a huge role in how long a levy 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.

Related: The IRS 10-Year Collection Statute – CSED Rules Explained

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

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:

• Offer in Compromise review
• Installment Agreement request review
• Collection Due Process (CDP) hearings or appeals
• Bankruptcy proceedings
• Time spent living outside the U.S.
• Military deferments
• Taxpayer Assistance Orders or litigation

Each tolling event adds time to the CSED clock—sometimes months or years.

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)

Strategic Use of the CSED to Stop or Prevent Levies

Knowing your CSED helps you:

• Avoid restarting the clock by filing at the wrong time
• Let the statute expire while in Currently Not Collectible status
• Push back against aggressive levies if expiration is near
• File a CAP or CDP appeal when enforcement is too close to the limit

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

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

FAQ: IRS Levies and the CSED

Q: How long can the IRS keep a levy in place?
A: Until the 10-year statute (CSED) expires—unless you trigger tolling or pay the debt.

Q: What if I’m close to my CSED expiring?
A: You may want to avoid taking actions (like an OIC) that pause the clock—unless it will resolve the debt entirely.

Q: Can the IRS collect after the CSED?
A: No. If they do, you may have grounds for a refund or legal claim.

Q: How do I know if my levy is illegal?
A: We can review your transcript and levy documents to determine if the CSED has passed.

📣 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.