Statute of Limitations for Collection of Tax from Taxpayer

A. The assessment of a tax imposes a lien on all of the taxpayer's tangible and intangible real and personal property. IRC 6321.

B. Under IRC 6502(a), the IRS has ten years from the assessment date to:

1. Collect the tax by administrative means (seizures, levies, offsets); or

2. Institute a suit for collection or a judgment.

C. 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).