february2021 - 20

FEATURE
Determining the Date of
for IRS Collection Purposes

Assessment

By Arnold van Dyk

GENERALLY, THE STATUTE of limitations (SOL) on IRS collection
enforcement is ten years from the date the tax is assessed. In
the Internal Revenue Manual (IRM), the IRS refers to the date
that ends the period in which collections may be enforced as
the Collection Statute Expiration Date, or CSED. Keep in mind
that if a return is audited or a taxpayer files an amended return
and additional tax is owed, the ten-year collection statute on
the additional taxes will be later than the original return's CSED.
Additionally, many penalties carry their own CSED date, including
the Estimated Tax Penalty, Deposit Penalty, Delinquency Penalty,
various civil penalties, Fraud Penalty, and the Negligence Penalty.
The first step in calculating the CSED
is determining the date of assessment
on the underlying liability. The date of
assessment is the date an assessment
officer signs the summary record.
Typically, the date of assessment is a few
weeks after the tax return is filed. It may
take the IRS a couple of months or more
to make the assessment in extenuating
circumstances. For example, mailing a
tax return to the wrong service center

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or the shutdown of IRS service centers
due to a pandemic may delay the date
the IRS assesses the tax.
So, how can the date of assessment
be obtained? One way to is to call the
IRS Practitioner Priority Service and ask
for the assessment date. Considering
there may be more than one CSED on a
taxpayer's account for any given tax year,
it is essential to inquire about all of the
potential CSEDs associated with the tax
year and the amount of tax associated
with each date. For an account where the
taxpayer filed his or her original return,
later filed an amended return, and later
audited, there may be several assessment
dates on the account, including separate
penalty assessment dates.
Another way to access the tax liability assessment date is by requesting IRS
transcripts of the taxpayer's account.
Tax practitioners with a valid Form 2848,
Power of Attorney and Declaration of
Representative, on file with the IRS may
contact the Practitioner Priority Service
by phone or access the transcripts
through IRS E-Services Transcript Delivery System (TDS). A tax practitioner will
need to sign-up for IRS E-Services before

using the online portal. The following
types of transcripts are available without
cost through IRS E-Services TDS or by
submitting IRS Form 4506-T, Request
for Transcript of Tax Return:
* Tax Return Transcript: Provides most
line data from the taxpayer's originally
filed return. This transcript is generally
accepted by mortgage and student loan
lenders. Tax Return Transcripts are
available for the current tax year and
three years prior, providing the taxpayer
filed the return(s). Keep in mind that the
Tax Return Transcript does not provide
any information about the account past
the filing of the return, including the date
of assessment of tax. It will also not reflect
any changes from an amended return.
* Tax Account Transcript: Provides general
data such as the type of return filed, filing
status, adjusted gross income, taxable
income, and all payments that have
been made. This transcript is especially
helpful because it provides a record of
the activities on the account after the
return was filed, such as the date of tax
assessment. Additional information that
may be obtained from this transcript
is the date and amounts of additional
payments made by the taxpayer, penalties
that were assessed, and if the return
was previously audited. When ordering
a Tax Account Transcript by phone or
using the Get Transcript by Mail feature
on IRS.gov, the IRS only provides the
current year and the prior three years'
Tax Account Transcripts. However,
Tax Account Transcripts are available
for the current year and the prior ten
years through IRS E-Services TDS and
by submitting the request through Form
4506-T. This is especially useful when
representing a taxpayer whose account
is in Collections and seven or eight years
have already passed.
* Record of Account Transcript: Combines
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