IRS Fresh Start Hub

The IRS 10-Year Collection Statute (CSED) and Fresh Start

Last reviewed September 2026Reviewed by the tax professionals at Global Gate Tax Relief

Short answer

Under IRC section 6502, the IRS generally has 10 years (IRS.gov, 2026) from the date a tax is assessed to collect it. That deadline is the Collection Statute Expiration Date (CSED). Each assessment has its own CSED. Events such as a pending payment plan request or offer, bankruptcy, a Collection Due Process hearing or a long stay abroad pause or extend it.

Key takeaways

  • The clock starts when the tax is assessed, not when it was due. Each assessment has its own CSED: the original return, an audit change, some penalties.
  • A pending installment agreement request or offer in compromise, bankruptcy, a Collection Due Process hearing, an innocent spouse request, combat zone service and living abroad for six months or more all pause or extend it.
  • A payment plan that is in effect does not pause the clock, and neither does currently not collectible status.
  • You can find the key dates on your IRS account transcript or by calling the IRS. If you think the IRS got it wrong, the Taxpayer Advocate Service can help.
  • Waiting out the statute is rarely a plan on its own. Interest keeps growing, refunds are kept, liens stay, and many common events add time.

How the 10-year collection statute works

Section 6502(a) of the tax code says that once a tax is assessed, the IRS may collect it by levy or by a court proceeding begun within 10 years after the assessment. The IRS explains the rule on its time IRS can collect tax page. The period covers the tax and the penalties and interest tied to it. The end of that period is the Collection Statute Expiration Date, or CSED.

Assessment is the start date, not the due date. The tax shown on a return is assessed when the IRS processes it, so a late return starts its clock later. If you never file, there is no assessment and no collection clock at all. The law lets the IRS assess tax for an unfiled year at any time (IRC 6501(c)(3)). It can also prepare a substitute for return and assess the tax itself.

Each assessment has its own CSED. The IRS lists examples: the tax on your original return, extra tax from an amended return or an audit, a substitute-for-return assessment, civil penalties and certain penalties and interest.

Example (assumed figures): you filed your 2021 return on time and the IRS assessed the tax on 23 May 2022. The CSED is 23 May 2032, unless something pauses it. An audit then adds more tax, assessed on 14 September 2024. That amount has its own CSED of 14 September 2034.

When a CSED passes, the IRS can no longer collect that assessment. It must release a filed lien within 30 days once the liability becomes legally unenforceable (IRC 6325(a)). If you pay after the CSED, you can ask for a refund of the overpayment before the refund statute runs out. There are two exceptions. A levy on future income made before the CSED can keep collecting. And if the government sues in time and wins a court judgment, it can collect for much longer. That is rare, but it is real.

The CSED is one of three IRS statutes of limitations. The other two are the time the IRS has to assess tax and the time you have to claim a refund.

How to find your CSED on your IRS transcript

  1. Get an account transcript for each tax year you owe. Sign in to your IRS Online Account, call the automated line at 800-908-9946, or file Form 4506-T. Ask for the account transcript, not the return transcript.
  2. Find the assessment date. In the Transactions section, transaction code (TC) 150 is the tax assessed from your return. Later assessments, such as TC 290 or TC 300 for additional tax, start their own clocks.
  3. Add 10 years. That is the starting CSED for each assessment.
  4. Look for codes that pause or extend it. Use the table below. Add the time between each starting code and its closing code, plus any extra days the law adds.
  5. Confirm with the IRS. The IRS says you can call 800-829-1040 (IRS.gov, 2026) (businesses 800-829-4933 (IRS.gov, 2026)) to confirm the last day it can collect. If you disagree with its answer, ask the Taxpayer Advocate Service for help on Form 911.
Transaction code What it means Effect on the CSED
TC 150 Tax assessed from your return Starts the clock for that amount
TC 290 / TC 300 Additional tax assessed (amended return, audit) Starts a separate clock for the additional amount
TC 971 action code 043 Installment agreement request pending Pauses it until the plan is set up (TC 971 AC 063) or the request is reversed (TC 972 AC 043)
TC 971 action code 163 Installment agreement terminated Adds 30 days
TC 480 Offer in compromise pending Pauses it until the offer closes (TC 481, 482 or 780), plus 30 days after a rejection and any appeal
TC 520 Bankruptcy or litigation, including a Collection Due Process hearing (closing codes 76 and 77) Pauses it until TC 521; bankruptcy adds six more months
TC 500 Military deferment, such as combat zone service Pauses it
TC 971 action code 065 Innocent spouse request Tracks a possible pause for the requesting spouse
TC 550 Statute extended by a signed waiver Moves the CSED to a new date
TC 534 Expired balance written off Shows the CSED has passed for that amount

Source: IRM 5.1.19 (collection statute expiration). Transcripts don’t show every internal code or closing code, and overlapping pauses are counted only once, so treat your own math as an estimate and confirm it with the IRS.

What pauses or extends the CSED

The IRS distinguishes two effects. A suspension pauses the clock while the IRS is barred by law from collecting. An extension adds time on top of the 10 years by law or by agreement. Both push the CSED later.

Event Effect on the CSED Law
Installment agreement request Paused while the request is pending. Adds 30 days if the request is rejected or withdrawn, or the IRS proposes to terminate the plan. Paused during an appeal. IRC 6331(k)(2)-(3), 6331(i)(5)
Installment agreement in effect No pause. The clock keeps running. IRS Tax Topic 202
Offer in compromise Paused while the offer is pending, for 30 days after a rejection, and during an appeal. IRC 6331(k)(1)
Collection Due Process hearing Paused from the request until the final determination, including court appeals. If fewer than 90 days remain afterward, the CSED becomes 90 days after the final determination. IRC 6330(e)
Bankruptcy Paused from the petition until the case is discharged, dismissed or closed, plus six months. IRC 6503(h)
Innocent spouse request Paused for the requesting spouse until a waiver is filed or the 90-day window to petition the Tax Court ends (or the court’s decision is final), plus 60 days. The other spouse’s CSED is not affected. IRC 6015(e)(2)
Combat zone service Paused while you are in the combat zone, plus 180 days. IRC 7508
Certain military service Paused for the period of service, plus 270 days from when the military notifies the IRS. Servicemembers Civil Relief Act
Living outside the U.S. Paused while you are abroad continuously for six months or more. The CSED won’t expire until at least six months after you return. IRC 6503(c)
Signed waiver (Form 900) Extends it to the agreed date. IRS policy limits this to certain partial payment agreements, for no more than five years plus one. IRC 6502(a)(2); IRM 5.14.2
Currently not collectible status Not on the IRS list of events that pause the clock. It keeps running. IRM 5.1.19

On a joint return, a pause can apply to only one spouse. That happens, for example, when only one of you files an offer, asks for a hearing or requests innocent spouse relief. The two of you can then end up with different CSEDs on the same tax year.

How the CSED interacts with each Fresh Start option

Option How the CSED matters
Simple Payment Plan The balance must be paid by the CSED (IRS.gov, July 2026). Older years have less time left, so the minimum payment on them is higher.
Guaranteed installment agreement Must be paid within 3 years (IRS.gov, July 2026), or by the CSED if that is sooner.
Lien withdrawal after a direct debit plan The plan must pay in full within 60 months (IRS.gov, 2026) or before the CSED, whichever is earlier.
Partial payment installment agreement Payments continue until each year’s CSED passes. Whatever is unpaid then can no longer be collected.
Currently not collectible The clock keeps running during CNC, so a balance can expire while collection is paused.
Offer in compromise The clock stops while the offer is pending. A rejected offer leaves you with more time on the clock than before you filed it.
Collection Due Process hearing Requesting a hearing (30 days (IRS.gov, 2026) from a levy notice) protects your appeal rights but pauses the clock for the whole hearing.

Example (assumed figures): a 2017 balance was assessed on 12 June 2018, so its CSED starts as 12 June 2028. You file an offer on 1 March 2025, and the IRS rejects it on 1 December 2025, 275 days later. You don’t appeal. The clock was paused for those 275 days plus 30 more, 305 days in all, so the CSED moves to about 13 April 2029. The IRS may count the days a little differently, so confirm the result.

Should you plan around the CSED?

The CSED is a legitimate part of choosing between options, and the IRS uses it the same way. A partial payment agreement or CNC status with only a few years left can cost far less than full payment, and an offer may not be worth filing if the statute is about to run out. What the CSED is not is a reliable escape hatch:

  • Interest and penalties keep growing for the whole period, and the IRS keeps any refunds you are due.
  • A filed lien stays until the CSED passes, which can affect selling or refinancing property.
  • Common events add time. Almost every request for relief pauses the clock while it is pending: plans, offers, hearings, innocent spouse claims, bankruptcy.
  • The IRS tracks expiring accounts. Its systems report accounts whose CSED falls within the next 12 months, and the IRS can levy, and in rare cases sue, before the date passes.
  • Unfiled years never start a clock. Leaving a return unfiled keeps that year open indefinitely.

Be wary of anyone who pitches “waiting out the IRS” as a product. Get your transcripts, work out the CSED for each year, and then pick the option that costs least over the time that is really left. You can do that yourself or with a representative. If you need the steps to request an option, see how to apply.

Frequently asked questions

Generally, yes. Under IRC 6502 the IRS has 10 years from each assessment to collect, and after the Collection Statute Expiration Date it can no longer collect that amount. The date moves later if something paused the clock, such as a pending offer, bankruptcy or a Collection Due Process hearing. A court judgment obtained in time can extend collection much longer.

Sources

  1. IRS: Time IRS can collect tax (reviewed 27 Jun 2026)
  2. IRM 5.1.19, Collection Statute Expiration (reviewed 11 May 2026)
  3. IRM 5.14.2, Partial Payment Installment Agreements and the CSED (6 Jun 2025)
  4. IRS Tax Topic 202, Tax payment options (reviewed 25 Sep 2026)
  5. IRS: Get transcript
  6. IRS: Offer in compromise
  7. IRS Publication 1660, Collection Appeal Rights
  8. 26 U.S.C. 6502, Collection after assessment
  9. 26 U.S.C. 6503, Suspension of running of period of limitation
  10. 26 U.S.C. 6331, Levy and distraint (subsections (i) and (k))
  11. 26 U.S.C. 6330, Notice and opportunity for hearing before levy
  12. 26 U.S.C. 6015, Relief from joint and several liability on joint return
  13. 26 U.S.C. 6501, Limitations on assessment and collection
  14. 26 U.S.C. 6325, Release of lien or discharge of property

We check every figure against IRS.gov and log changes on the key figures page.

Want a professional to look at your options?

Free consultation, no obligation. If we take your case, the flat fee is quoted upfront before any work begins. If you can handle it yourself through IRS.gov, we will tell you. No outcome is guaranteed.

Request a free consultationCall 1-877-800-8180

This page is general information about IRS rules, not tax or legal advice for your situation. IRS figures change; each one links to its official source and the date we last checked it.