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As A Result Of TAS Advocacy, The IRS Is Working To Address A Computer Glitch That Allowed Collection Activity On Accounts With Expired Collection Statute Expiration Dates But Many Issues Remain Unresolved | TaxConnections
About two years ago, TAS received cases where either the taxpayer or the Power of Attorney (POA) correctly questioned the validity of a collection statute expiration date (CSED) calculation while working with Collection. Based on the cases we were seeing, TAS looked deeper and identified a systemic problem. Working together, TAS Case Advocacy and Systemic Advocacy identified affected cases and are working to make sure accounts are corrected and refunds (where applicable) are issued. But this is a complicated issue that involves a case-by-case review. I want to get the word out about this problem so taxpayers or their representatives are empowered to advocate for themselves or their clients. Generally, IRC § 6502 provides for the statutory limitation period for collection. The IRS refers to the end date of this time period as the Collection Statute Expiration Date, or CSED. Treasury Regulation § 301.6159-1(g) tolls the CSED while an installment agreement (IA) is pending, or 30 days after an IA is terminated or rejected, and during any appeal of that decision. The problem TAS has identified centers around a computer glitch that tolled the CSED for an inordinate amount of time in certain case types involving IAs. The five “buckets” of cases that TAS examined involve the following types of cases: