When I obtain transcripts from the IRS for my clients I always look for the day the tax was assessed because the IRS only has 10 years to collect the debt. However, there are some events that can occur over that period of time that stops the Statute of Limitations temporarily. They include offers in compromise, collection due process hearings, requests for installment agreements, and bankruptcies.
There is also another way the IRS can continue to go after a taxpayer. That is if they file a lawsuit in Federal District Court to obtain a judgment for another 20 years. This is not done on a regular basis, but in cases involving homes (even homesteads) that they want to seize or cases where there is an excellent chance for them to collect what is owed, the local Revenue Officer may refer the case to the Department of Justice. The DOJ may or may not take the case, but if they decide that it is in the Government’s best interest, they will sue the taxpayer.
This has happened in two recent cases of mine. One involves a significant amount of money owed. The other involves a taxpayer who owns a house with considerable equity that would almost fully pay a large IRS debt. In both instances, I am trying to work out a deal that is in everyone’s best interest.
Many taxpayers who owe the IRS and are coming up on 10 years are counting the days. Just keep in mind that it is not over until we are sure it is over.
Steven N. Klitzner, P.A. is a tax attorney based in Miami, Florida. He has been practicing tax law for over 40 years, and currently holds a 10.0 rating by Avvo. Mr. Klitzner was appointed to the IRS Service Advisory Council in 2021 and is... 
