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Collection & EnforcementIRC § 6502IRM 5.14.1

CSED (Collection Statute Expiration Date)

Definition

The CSED is the expiration date on the IRS's legal authority to collect a tax debt — generally 10 years from the date of assessment under IRC § 6502.

Why This Matters for Tax Relief

The CSED is one of the most strategically significant concepts in tax relief, yet most taxpayers are never told it exists. Under IRC § 6502, the IRS has exactly 10 years from the date a tax liability is formally assessed to collect that debt. Once the CSED passes, the debt is legally extinguished and the IRS must release all related federal tax liens. The critical complication is that the CSED is a moving target. Specific events called 'Tolling Events' legally pause the 10-year clock. Filing an Offer in Compromise suspends the CSED for the entire period the offer is under consideration plus 30 days after rejection. Filing for bankruptcy pauses the clock for the duration of the case plus 6 months. Requesting a Collection Due Process (CDP) hearing under IRC § 6330 also tolls the statute. Each tolling event adds time to the back end of the CSED, often extending it by years. Never file for bankruptcy or submit an OIC without first calculating the impact on your CSED.

2026 Update

In 2026, with the underpayment interest rate at 6% (Q2), waiting out a CSED carries significant cost. On a $50,000 balance, interest accrues at approximately $8.22 per day. A CSED strategy must weigh the cost of continued accrual against the relief of statute expiration.

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