Statute of Limitation for Collection of Tax from Taxpayer
- The assessment of a tax imposes a lien on all of the taxpayer's tangible and intangible real and personal property
- Under IRC § 6502(a), the IRS has ten years from the assessment date to:
- Collect the tax by administrative means (seizures, levies, offsets); or
- Institute a suit for collections or a judgment.
- If IRS commences timely suit to collect tax or obtain a judgment, then it may continue its efforts to administratively collect the tax beyond the ten-year period. IRC § 6502(a).
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Tax
