IRS Code Section 6502: Collection Periods and Deadlines

Overview

IRS Code Section 6502 governs how long the federal government has to collect an assessed tax liability. In plain terms: once the IRS formally assesses a tax, it generally has 10 years to collect that debt. That 10-year window is commonly called the Collection Statute Expiration Date (CSED) or simply the collection statute.

This rule matters because it defines how long the IRS can pursue enforced collections such as liens, levies, and wage garnishments. In my 15+ years as a CPA working with clients across Texas and nationally, I’ve seen taxpayers avoid unnecessary payments or litigation simply by confirming whether their CSED had passed. Conversely, failing to track the CSED can leave you exposed to surprise collection actions.

Authoritative references include the Internal Revenue Code (26 U.S.C. § 6502) and IRS guidance (Publication 594). See the law text (Cornell Law) and IRS Pub 594 for the complete legal framework (cite: 26 U.S.C. §6502; IRS Publication 594).

How the 10-year period starts

• The collection period begins on the date of assessment, not the date you filed your return or the date a notice was mailed. “Assessment” is the official recording of the tax liability on the IRS books.
• For most individual returns, assessment occurs when the IRS processes the return and posts the tax to the account. For assessments tied to audits or amended returns, the assessment date is when the IRS formally records that assessment.

Practical step: to confirm the assessment date, request an account transcript via IRS Get Transcript or ask your tax professional to pull a Record of Account. That date drives your CSED.

When the 10‑year period can stop, pause, or be extended

The 10-year clock is not absolute. Certain events can pause (toll) or extend the collection period. Common examples include:

• Signed consents to extend the statute (Form 872 or similar agreements).
• Periods when the taxpayer is insolvent or subject to a bankruptcy proceeding—bankruptcy filings generally suspend (toll) IRS collection activity while the bankruptcy is in effect and often for a statutory period afterward (see IRS Pub 594).
• The time the IRS is prevented from collecting due to service outside the United States or the taxpayer’s absence.
• When the taxpayer files an Offer in Compromise and the IRS is considering it, or when a Collection Due Process (CDP) hearing or appeal is pending (the law provides for tolling in various administrative proceedings).
• Certain litigation or lawful suspension under 26 U.S.C. §6503.

Because the rules are specific and fact-dependent, always confirm which statutory suspensions apply to your situation. IRS Publication 594 and the statutory text of 26 U.S.C. §6503 list common tolling situations.

What doesn’t typically extend the period

• Making a payment does not reset the 10-year period by itself. Payments reduce the balance owed but usually do not extend the CSED unless accompanied by an executed extension agreement.
• Simple delays or correspondence that do not meet the statutory criteria for tolling will not stop the clock.

Examples from practice

• Case A: A client had an assessment dated June 15, 2014. Their CSED was June 15, 2024. We confirmed there had been no Form 872 or bankruptcy filing, so the client’s liability became unenforceable after the CSED passed.
• Case B: A small business owner had an assessment in 2011 but filed bankruptcy in 2014. The bankruptcy tolling and other suspensions altered the effective CSED calculation. We worked with the transcripts and bankruptcy docket to compute the adjusted expiration date.

These examples illustrate why plain calendar math isn’t enough—you must review the administrative record for any tolling events or consents to extend.

How to find and verify your Collection Statute Expiration Date (CSED)

1. Order transcripts

• Request an Account Transcript or Record of Account from the IRS (Get Transcript online or by mail). The transcript shows the assessment date(s) and many collection actions. IRS Publication 594 explains how the CSED is calculated.

1. Review IRS notices and internal consents

• Look for any copies of Form 872 (agreement to extend the statute) or notices showing pending appeals, offers, or bankruptcy filings.

1. Check for tolling events

• Confirm whether the taxpayer was in bankruptcy, had an Offer in Compromise pending, or was outside the U.S. for relevant periods. These items are often documented in IRS records and can appear on transcripts.

1. When in doubt, get professional help

• Calculating the adjusted CSED after tolling events or consent agreements often requires professional review of account transcripts and legal documents.

Practical strategies while CSED is active

• Negotiate an installment agreement if you can pay over time. (See our guide: Installment Agreements Explained: Types, Qualifications, and Costs.)
• Consider an Offer in Compromise only after you’ve confirmed the CSED and evaluated whether an offer merits the administrative tolling that could extend collection exposure.
• Prioritize getting your IRS account transcript and documenting all communications with the IRS.

Useful internal resources:

• Installment agreements (how to apply and pros/cons): “Installment Agreements Explained: Types, Qualifications, and Costs” (https://finhelp.io/glossary/installment-agreements-explained-types-qualifications-and-costs/).
• Statute of limitations primer: “Statute of Limitations for Taxes: Filing, Assessment, and Collection” (https://finhelp.io/glossary/statute-of-limitations-for-taxes-filing-assessment-and-collection/).
• If lien or levy is a concern: “Tax Liens and Levies: What They Mean and How to Stop Them” (https://finhelp.io/glossary/tax-liens-and-levies-what-they-mean-and-how-to-stop-them/).

Common misconceptions and traps

• Misconception: “If I ignore the IRS, the debt will go away after 10 years.” Not always—if there were tolling events, the debt’s enforceable period may be extended. Also, some tax liabilities (for example, certain penalties tied to fraud or unfiled returns) affect the assessment period rather than collection, so the timing can be complex.

• Trap: Thinking payments stop the clock. Payments reduce the balance but won’t necessarily shorten or restart the CSED calculation.

• Misreading notices: A notice that says the IRS is “assessing” or “considering” may not be a final assessment date. Always confirm the formal assessment date from your IRS account transcript.

When the IRS can still collect after the CSED

If the IRS attempts collection after the CSED has passed, you (or your representative) can challenge the action. Often the IRS will release liens or reverse levies if the CSED has expired, but you may need to provide documentation or file a request. If the IRS has taken funds in error after the CSED, a prompt appeal or refund claim is appropriate.

Interaction with bankruptcy and Offers in Compromise

• Bankruptcy: A bankruptcy filing commonly stays collection activity. The suspension periods and post-bankruptcy rules are complex; the CSED is often tolled during the bankruptcy and for defined statutory periods after.
• Offers in Compromise: Submitting an offer can pause certain collection actions while the offer is pending. However, if the offer is rejected or later defaulted, the underlying CSED computation must be revisited.

For both, work with a tax attorney or CPA who understands practice before the IRS and bankruptcy courts.

Action checklist (what to do now)

1. Order your IRS Account Transcript and Record of Account.
2. Identify the assessment date(s) and any Form 872 or extensions.
3. Look for evidence of tolling events (bankruptcy, offers, appeals, absence from U.S.).
4. If your CSED is near or past expiration, consult a tax professional to confirm and to prepare any required steps to lift liens or stop levies.
5. If you need to pay, consider an installment agreement—learn more in our Installment Agreements guide.

Frequently asked questions

• How do I get the IRS to confirm my CSED in writing? Request account transcripts and, if needed, submit a written request to the IRS or work through a practitioner. The IRS won’t typically send a stand‑alone CSED letter; it’s derived from account history.

• Can the IRS revive a tax after the CSED expires? Generally no — after the CSED passes, the IRS lacks authority to collect the assessed tax. However, exceptions can occur if the statute was validly extended or tolled.

• Does bankruptcy eliminate the tax? Bankruptcy rules are nuanced. Some tax debts may be dischargeable; others are not. Bankruptcy usually pauses collection but doesn’t automatically erase the debt outside of formal discharge rules.

Final thoughts and professional disclaimer

Understanding the collection statute is one of the highest‑value actions a taxpayer can take when managing unpaid federal taxes. In my practice, confirming the assessment date and reviewing account transcripts has often led to quicker, less costly resolutions.

This article is educational and does not constitute personalized tax advice. For guidance tailored to your facts, consult a qualified CPA, tax attorney, or enrolled agent. Primary sources: IRS Publication 594 (The Collection Process) and 26 U.S.C. § 6502 (collection after assessment) (see IRS and Cornell Law for the statute text).

References

• IRS, Publication 594, The Collection Process (see https://www.irs.gov/publications/p594).
• 26 U.S.C. § 6502 — Collection after assessment (Cornell Legal Information Institute): https://www.law.cornell.edu/uscode/text/26/6502
• IRS Tax Topic and Collection guidance (see IRS.gov).