The Collection Statute Expiration Date (CSED) is the last day the IRS can legally collect a specific, assessed tax (called a “module”). The IRS states it plainly: “The IRS generally has 10 years – from the date your tax was assessed – to collect.” See Time IRS can collect tax.

The 10-year period starts on the assessment date, not the filing date, and each assessment creates its own clock. Common assessment types include:

• Your original self-assessed return (TC 150)
• Additional tax from an audit (TC 300)
• Amended return increases (TC 290)
• Substitute for Return (SFR) assessments
• Certain civil penalties

Because assessments can occur at different times, you may have multiple overlapping CSEDs across years—and even within the same year. Understanding this is critical for strategy.

Strategic importance: If some modules are months from expiring, you might avoid actions that toll (pause) the clock unless they deliver clear value. If you have years remaining, tools like an Offer in Compromise may be worth the pause.

Ed Parsons, CPA builds a day-accurate timeline from your IRS transcripts—per module—so you don’t guess. With the calendar right, Ed designs a plan that avoids gifting the IRS more time than the law allows. Start with a confidential consultation.

“Tolling” means a legal suspension of the CSED—time during which the IRS is prohibited from collecting, so the 10-year clock stops. In some situations, the law also adds extra days after the suspension ends.

The IRS maintains a current list at Time IRS can collect tax. Major tolling events include:

• Installment Agreement request pending, plus 30 days after rejection/withdrawal/termination, and during appeal
• Bankruptcy—suspends from petition to discharge/dismissal/closure plus 6 months afterward
• Offer in Compromise pending; +30 days after rejection; suspension continues during appeal
• Collection Due Process hearing—timely Form 12153 suspends from IRS receipt to final determination, including court review
• Innocent Spouse Relief—suspends while pending; continues through Tax Court; +60 days after
• Combat zone/SCRA protections
• Overseas residence (6+ months)
• Assets in custody of a court

Critical detail: If fewer than 90 days remained when a CDP determination becomes final, your CSED is extended to 90 days after that determination.

Ed Parsons, CPA reconciles every tolling period from transcripts and notices, then aligns your actions (IA/CDP/OIC/etc.) with your goals so you don’t accidentally extend the government’s clock for no benefit. Talk with Ed about strategic timing.

You can view key indicators via Your Online Account and Account Transcripts. On transcripts, assessments appear as TC 150/290/300; tolling periods are flagged by codes like:

• TC 480/481/482 (OIC periods)
• TC 520/521 (CDP, litigation, bankruptcy)
• Various TC 971 action codes

The IRS maintains an internal “computed CSED,” but it’s only as accurate as the underlying coding. Dates can be wrong if a tolling event was mis-coded, never properly closed, or tied to another module.

Why professionals recompute from transactions: We start with assessment dates, identify all start/stop tolling periods, then add the fixed extensions (e.g., +30 days after OIC rejection, +6 months after bankruptcy, 90-day minimum after CDP determination when <90 remained).

When IRS dates are wrong: Your representative can escalate for correction. When harm is imminent, consider the Taxpayer Advocate Service with Form 911.

Ed Parsons, CPA pulls complete transcripts under Form 2848 and delivers a day-accurate CSED calendar per module—with documentation to fix IRS errors. It’s the difference between hoping and knowing. Get your accurate CSED calendar from Ed.

No—CNC, by itself, doesn’t automatically suspend the 10-year period. CNC means the IRS temporarily delays collection because paying would cause hardship. See Temporarily Delay the Collection Process.

Where confusion happens: CNC is often requested during or after other actions (CDP, IA requests, OIC attempts) that do toll the statute. The tolling comes from those other actions, not the CNC status itself.

Strategic value of CNC: Used correctly, CNC can be a powerful tool to protect wages and bank accounts while the 10-year clock keeps running. This can be ideal when you’re close to CSED expiration on key modules.

CNC requirements: You must remain compliant (file on time, adjust withholdings/estimates) and respond to periodic financial reviews. If your situation improves materially, the IRS can remove CNC and resume active collection.

Ed Parsons, CPA screens you for CNC eligibility with a reality-based budget, not guesswork, and walks the line between needed protection and unnecessary tolling. If you’re near CSED on key modules, Ed times requests so you don’t accidentally add months to the clock through adjacent actions. Get CNC strategy aligned with your CSED calendar.

Requesting an Installment Agreement can suspend the CSED while the request is pending, and the clock is extended 30 days after a rejection, withdrawal, or proposed termination. The clock is also suspended during an appeal of those decisions.

See the IRS’s CSED list: Time IRS can collect tax and the Online Payment Agreement application.

IAs aren’t necessarily bad: A well-timed IA can stop levies and protect your cash flow while you resolve the balance or let near-expiring modules run out. The key is timing and structure:

• Requesting the IA when needed (not prematurely)
• Paying an amount you can sustain
• Avoiding needless reconsiderations that create extra tolling
• Strategic payment allocation when multiple modules have different CSEDs

Strategic considerations: If multiple modules have different CSEDs, payment allocation matters so you don’t overpay expiring tax while leaving newer balances intact.

Ed Parsons, CPA models your module-by-module calendar and designs an IA that protects you without gifting the IRS avoidable time. He also documents any appeal of a rejection/termination so you don’t accidentally extend more than necessary. Get IA strategy aligned with your CSED timeline.

An OIC can be the right tool if you’re eligible. While an offer is pending, the CSED suspends; if the IRS rejects your offer, the CSED is extended 30 days; and if you appeal, the suspension continues through Appeals’ decision.

See: Offer in Compromise overview and the CSED list.

Where OIC backfires on CSED: When taxpayers file weak offers just to “buy time.” Reality: You don’t buy time—you give it. If the offer is never viable, you may add months (or more) to the collection window and emerge with the same balance and fewer options.

When OIC makes sense: A strong, well-documented offer can reduce the debt materially, making the temporary suspension worthwhile. The key is realistic qualification based on your actual Reasonable Collection Potential (RCP).

CSED considerations for OIC timing:

• If you’re months from CSED expiration, the tolling may cost more than the potential settlement saves
• If you have years remaining, OIC tolling is less concerning
• Multiple modules with different CSEDs require careful analysis

Ed Parsons, CPA screens OICs with a full financial analysis, transcript-based CSED modeling, and IRS reasonableness standards—before filing. If the numbers say “yes,” Ed builds an examiner-ready offer. If they say “no,” he won’t waste your calendar; he’ll pivot to IA/CNC/CDP strategies that protect you. Get professional OIC qualification analysis.

A timely CDP request (Form 12153) suspends the CSED from the date the IRS receives your request until you withdraw it or a final determination is made (including court review). If fewer than 90 days remained when the determination became final, your CSED is extended to 90 days after that determination.

See CDP FAQs and the CSED list.

Equivalent Hearing (EH) provides a similar Appeals review when a CDP request is late, but EH does not suspend the CSED. This is a critical difference for timing-sensitive situations.

Strategic CDP considerations:

• If levy is imminent and you need protected Appeals forum to pursue IA/CNC/OIC, CDP tolling is often worth it
• If you’re very close to CSED, consider alternatives (narrowly tailored IA or CNC) that protect you without substantial tolling
• The 90-day minimum rule can actually help if you’re down to weeks remaining

Timing is everything: CDP is a strategic decision that requires accurate CSED calculation and risk assessment of immediate enforcement versus long-term collection exposure.

Ed Parsons, CPA evaluates CDP timing strategically. If levy is imminent and you need a protected Appeals forum, CDP may be worth the tolling. If you’re very close to CSED, Ed may recommend alternatives that protect you without giving the IRS additional months. Get strategic CDP timing advice from Ed.

Bankruptcy: The CSED is suspended from the petition date until the case is discharged, dismissed, or closed, and then extended by 6 months. See Publication 908 and the IRS CSED list.

Dischargeability considerations: Whether tax is dischargeable depends on complex rules including timing of filing, type of tax, fraud issues, and whether returns were filed. Not all tax debt is dischargeable in bankruptcy.

Court control of assets (probate/receivership): When a taxpayer’s assets are in the custody of a court, collection is suspended and the CSED tolls during that period. This can occur in estate situations or business receiverships.

Judgment/Litigation: Reducing a tax to judgment, or certain suits, can extend or suspend the collection period. The IRS can pursue litigation to protect its collection rights when the statute is approaching expiration.

CSED calculation complexity: These scenarios create complex tolling calculations that require careful transcript analysis and legal coordination. The suspension periods must be precisely calculated, and the IRS’s internal systems don’t always reflect the correct dates.

Ed Parsons, CPA coordinates with counsel when bankruptcy or litigation is involved, computes the post-event CSED accurately, and ensures the IRS records reflect the correct suspension/extension periods. You get a realistic timeline and a plan that fits your legal posture. Get coordinated CSED and legal strategy from Ed.

Often, yes. If you’re outside the United States continuously for at least six months, IRC 6503(c) suspends the collection period while you’re abroad; the IRS may also extend the CSED by at least 6 months upon your return.

See the IRS CSED list for current guidance.

Common expat surprise: Many expats assume the 10-year clock keeps running while they’re overseas. This can be a costly assumption if your resolution strategy depends on CSED expiring on schedule.

Documentation requirements: If your plan depends on CSED expiring, you need to model travel/residence dates precisely and gather proof:

• Passport stamps and visa records
• Overseas lease agreements
• Foreign employer letters
• Bank records showing overseas transactions

Complex interaction: Remember that other events (OIC, CDP, IA requests) could also have tolled the statute during your time abroad, creating layered tolling periods that require careful calculation.

Ed Parsons, CPA reconstructs your residence timeline, reconciles it to transcripts, and computes a correct CSED—before he advises on IA/CNC/OIC/CDP options. If the IRS’s systemic date ignores foreign-residence tolling, Ed documents the correction and pursues an update. Avoid CSED surprises—consult Ed about overseas tolling.

Filing Form 8857, Request for Innocent Spouse Relief, can suspend the CSED while the claim is pending; if you petition Tax Court, the suspension continues until the court’s final decision; afterward the IRS generally adds 60 days.

See the IRS CSED list, About Form 8857, and Publication 971.

Key nuance for joint returns: On a joint module, the requesting spouse’s CSED suspends, but the non-requesting spouse’s CSED may not—depending on circumstances. This means spouses can wind up with different clocks on the same year.

Strategic considerations:

• Timing Form 8857 with other collection alternatives (IA/CNC/OIC)
• Coordinating relief requests to avoid needless tolling that doesn’t benefit both parties
• Understanding how relief affects joint vs. separate liability
• Managing different CSED timelines for each spouse

Complex eligibility rules: Innocent spouse relief has specific qualification requirements including knowledge standards, economic hardship factors, and timing limitations that require careful evaluation.

Ed Parsons, CPA evaluates innocent spouse eligibility, coordinates relief with the broader collection plan, and models how Form 8857 affects both spouses’ CSEDs. He also handles IRS communications so sensitive details are presented professionally and deadlines aren’t missed. Get coordinated innocent spouse and CSED strategy from Ed.

Most common CSED mistakes:

• Filing a weak OIC just to “buy time.” Reality: OIC suspends the clock and, if rejected, adds 30 days—you likely end up with more time for the IRS and no settlement
• Requesting an IA too early or repeatedly. Each request tolls while pending and adds 30 days after adverse actions; appeals also toll the clock
• CDP timing errors. Timely CDP suspends—great for protection, but costly when you’re weeks from CSED. Equivalent Hearing doesn’t suspend—useful if you only want Appeals review without gifting time
• Ignoring expat tolling and military/combat-zone rules. Your clock may not be running when you think it is
• Assuming CNC pauses CSED. It doesn’t—though adjacent actions might

How Ed avoids these mistakes: By creating a module-by-module CSED calendar first, then choosing the lowest-toll route to your goal (IA, CNC, OIC, CDP). He audits IRS dates for errors and corrects them when needed.

Ed’s systematic approach:

• Pull complete transcripts and compute day-accurate CSEDs per module
• Identify and correct IRS coding errors
• Model tolling impact of each available strategy
• Choose the path that provides needed protection with minimal time gift to IRS
• Monitor and document all tolling periods going forward

See IRM/IRS resources: CSED list, Publication 594, IRM 5.1.19.

Ed Parsons, CPA prevents these costly mistakes by getting the calendar right first, then executing the strategy that protects you with the least tolling impact. Work with Ed to avoid CSED mistakes.

Yes. Because each assessment has its own CSED, a smart plan considers payment allocation so you don’t pour cash into balances that are about to expire while newer balances hang around.

Payment allocation complexity: The IRS applies payments by rules that may not match your intent unless you structure things correctly. This requires understanding their internal allocation methodology and working within it strategically.

Strategic considerations:

• Identifying which modules are closest to CSED expiration
• Structuring agreements to minimize payments on near-expiring balances
• Understanding how IA requests and appeals toll different modules
• Balancing CSED strategy with levy protection needs

Timing nuances: Remember that IA requests and appeals toll the clock. Sometimes there’s little point in paying down a module that will naturally time out in weeks—unless doing so unlocks a better global solution (removes a levy, qualifies you for a streamlined IA).

Ed Parsons, CPA models module timelines and designs an IA or CNC/OIC pathway that meets compliance while minimizing overpayment risk. He’ll also tell you bluntly if there’s little point in paying down a module that will naturally expire soon—unless it serves a larger strategic purpose. Get calendar-aligned payment strategy from Ed.

Yes. A timely CDP request (Form 12153) stops levy and suspends collection while Appeals reviews your case. See CDP FAQs.

When you’re very close to CSED: You and your representative should compare CDP to alternatives like a narrow Installment Agreement or CNC that can protect you without substantial tolling. The right answer depends on how much time is left and the risk of enforcement.

The CDP 90-day rule: If the IRS proposes immediate action and you have less than 90 days left, remember the CDP rule that ensures a 90-day minimum after a final determination. Sometimes that extra breathing room is worth it to lock in a sustainable deal; other times, it’s better to avoid extending the clock.

Alternative protection strategies:

• Narrow IA with minimal tolling impact
• CNC hardship status (no CSED tolling)
• Combination approaches timed to your specific calendar

Emergency considerations: When levy is imminent, you may need immediate action to protect wages and bank accounts, even if it means some CSED tolling. The key is making an informed trade-off rather than a panic decision.

Ed Parsons, CPA triages levy risk, calendars exact CSED days, and picks the lowest-toll path that still protects your wages and bank accounts. He then executes the filings and negotiates with Collections/Appeals. Need emergency levy protection? Contact Ed now.

First, get the calendar right. Pull transcripts and compute a day-level CSED for each module. See the IRS guide for basics, but professional computation is critical for accuracy.

Then choose the lightest-toll tool that still protects you:

• A narrow Installment Agreement might be better than CDP if the goal is to cross the finish line without giving the IRS extra months
• CNC provides protection without CSED tolling if you qualify for hardship status
• If levy is imminent and unavoidable, a timely CDP can stop enforcement but will suspend the clock

Critical documentation: Document every submission (certified mail, fax confirmations, upload receipts). Stay compliant on current-year filings so you don’t trigger new assessments that restart the collection cycle.

Timing considerations: Weigh the trade-off between immediate protection and long-term CSED impact carefully. Sometimes accepting some collection pressure for a few more weeks or months is worth avoiding years of additional collection exposure.

Ed Parsons, CPA specializes in these high-pressure, timing-sensitive situations. Under collection pressure, mistakes are costly. Ed triages levy risk, constructs your CSED map, and executes the lowest-toll, highest-protection route—then monitors dates so you don’t get surprised. Hand this off to Ed for immediate professional triage.

Because CSED is a calendar problem disguised as a tax problem. You need someone who:

1. Builds day-accurate CSED models per module from IRS transcripts (TC 150/290/300, 480/481/482, 520/521, 971 codes)
2. Chooses actions strategically (IA/CNC/OIC/CDP) that protect you without gifting time unnecessarily
3. Fixes mis-computed CSEDs and escalates through the IRS when systems are wrong—using Form 911 if hardship exists
4. Negotiates with Collections and Appeals to convert the plan into signed, enforceable relief
5. Keeps you quietly compliant going forward so you don’t restart the collection cycle

Ed’s systematic approach:

• Comprehensive transcript analysis and CSED calculation
• Strategic timing of all collection alternatives
• Error identification and correction with IRS systems
• Professional representation throughout the process
• Ongoing compliance monitoring and support

Technical expertise: Read about Ed’s approach to transcript analysis in his Definitive Guide to IRS Transcripts. This level of technical depth is what separates accurate CSED work from guesswork.

The bottom line: CSED mistakes can cost you years of additional collection exposure. Ed’s precision prevents those mistakes and positions you for the best possible outcome.

When you’re ready for clock-smart action with professional execution, contact Ed Parsons, CPA.

When the collection statute expires, the IRS generally must stop collecting that module and release the federal tax lien for that assessed liability (subject to limited exceptions).

See Publication 594 for the general collection process and lien release context.

Important caveats:

• If the IRS mis-computed the CSED or believes tolling periods extend it, they may continue collection until corrected
• New assessments (from later audits) have their own clocks and aren’t affected by expired CSEDs on other modules
• You want documented proof of expiration and formal lien release where appropriate

Practical reality: The IRS’s internal systems don’t always automatically stop collection or release liens when CSED expires. Manual intervention and follow-up are often required to ensure proper implementation.

Verification process: You need confirmation that the IRS recognizes the expiration and has updated their systems accordingly. This includes stopping collection activities and releasing any liens related to the expired modules.

Ed Parsons, CPA confirms expiration to the day, documents the file with proper legal support, and pursues lien release where appropriate. If the IRS’s system is wrong, he escalates with transcripts, law citations, and—when hardship exists—TAS involvement. Don’t assume expiration is automatic—verify with Ed.

Yes, in certain litigation and judgment scenarios the government can extend or suspend the collection period. The detailed rules are complex and found in the Internal Revenue Code and IRS procedures.

For practical guidance, see IRM 5.12.8, Refiling of the Notice of Federal Tax Lien, which includes events that extend or suspend the CSED, and the CSED overview: IRM 5.1.19.

Lien refiling clarification: Lien refiling itself doesn’t extend the CSED; it preserves notice priority if the statute is still open. But the decision to sue, reduce to judgment, or pursue foreclosure can affect CSED and is fact-specific.

When IRS considers litigation:

• Large balances with substantial assets or equity
• Cases where the taxpayer has significant collection potential
• Situations where normal collection tools are insufficient
• Strategic decisions to preserve government interests

Relatively rare in routine cases: Judgment actions are uncommon in typical individual tax cases but can occur when substantial assets or complex legal issues are involved.

Ed Parsons, CPA monitors transcript codes (TC 520/521) that indicate litigation considerations and coordinates with counsel when court proceedings are contemplated. If the Service is considering suit, you want CSED math and lien posture exactly right. Get precise CSED analysis when litigation is a risk.

Essential IRS Resources for CSED:

• Time IRS can collect tax (CSED list and examples)
• Publication 594 — The IRS Collection Process
• Publication 908 — Bankruptcy Tax Guide
• Offer in Compromise (overview)
• Online Payment Agreement (apply online)
• Temporarily Delay Collection Process (CNC)
• CDP FAQs (Form 12153)

Technical IRS Resources:

• IRM 5.1.19 — Collection Statute Expiration
• IRM 5.12.8 — Lien Refiling (CSED impacts)
• About Form 8857 (Innocent Spouse)
• Publication 971 (Innocent Spouse Relief)
• Combat Zone Q&A

Beyond reading—professional application: While these resources provide the framework, applying CSED rules to your specific situation requires professional analysis. Transcript interpretation, tolling calculations, and strategic timing decisions require expertise and experience.

When you want these rules applied to your file—not just read about—start with Ed Parsons, CPA.