Collection Statute Expiration Date (CSED) Strategy

Categories: IRS CE, IRS Resolution
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About Course

This two-hour continuing education course provides tax professionals with a technical, practice-ready framework for calculating and strategically applying the Collection Statute Expiration Date (CSED) under IRC Section 6502. While the CSED is mentioned elsewhere in this catalog as a side effect of Currently Not Collectible status, this course addresses the CSED as its own strategic subject — the full range of suspension and tolling events across installment agreements, Offers in Compromise, Collection Due Process hearings, bankruptcy, taxpayer absence, and statute waivers — rather than as a byproduct of any single collection alternative.

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What Will You Learn?

  • Apply IRC Section 6502 to determine the base 10-year collection statute expiration date and distinguish it from the assessment statute of limitations
  • Explain the effect of multiple assessments on the same tax period on the CSED calculation, and the consequences of collection action after the CSED has expired
  • Apply IRC Section 6331(k) to calculate CSED suspension during a pending installment agreement or Offer in Compromise
  • Apply IRC Section 6330(e)(1) to calculate CSED suspension during a pending Collection Due Process hearing, including the 90-day floor rule
  • Apply IRC Section 6503(h) and Section 6503(c) to calculate CSED suspension during bankruptcy and periods of taxpayer absence from the United States
  • Identify the current, restricted circumstances under which a Form 900 CSED waiver may properly be used
  • Independently verify a client's CSED using IRS account transcripts and identify common IRS calculation errors
  • Evaluate when allowing the CSED to run is preferable to active resolution, and apply Circular 230 considerations to CSED-related client counseling

Course Content

Module 1 – The CSED Framework — Section 6502, the 10-Year Rule, and Calculating the Base Date
<p>The CSED Framework — Section 6502, the 10-Year Rule, and Calculating the Base Date</p>

  • The CSED Framework — Section 6502, the 10-Year Rule, and Calculating the Base Date

Module 2 – Tolling Events I — Installment Agreements, Offers in Compromise, and CDP Hearings
<p>Tolling Events I — Installment Agreements, Offers in Compromise, and CDP Hearings</p>

Module 3 – Tolling Events II — Bankruptcy, Taxpayer Absence, Statute Waivers, and Judgment
<p>Tolling Events II — Bankruptcy, Taxpayer Absence, Statute Waivers, and Judgment</p>

Module 4 – Practitioner Strategy — Verifying the CSED, Common Errors, and Client Counseling
<p>Practitioner Strategy — Verifying the CSED, Common Errors, and Client Counseling</p>

Final Assessment – Collection Statute Expiration Date (CSED) Strategy
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

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