Statute of limitations (SOL) on collection actions

We have 20 years to collect on a liability (R&TC 19255).

Start of 20-year SOL

Generally, we can collect unpaid tax liabilities for up to 20 years after the date the latest tax liability becomes due and payable for that tax year. (R&TC 19255)

The latest tax liability may include but is not limited to the following:

  • Collection cost recovery fee
  • Lien fee
  • Installment agreement fee (payment plans)
  • Final notice of proposed assessment

There are certain penalties that have their own SOL such as:


  • You have a $20K tax liability that became collectable in tax year 2000
  • You have not resolved that liability
  • In tax year 2008, we asses a collection cost fee
    • Our assessment resets the 20-year SOL

Tolling (suspend)

The 20-year SOL is suspended when we cannot collect your balance due because of the following:

  • Bankruptcy
  • Payment plans
  • Service member deployed in a combat zone
  • Child support collections
  • Federally declared disaster, terrorist attack, or military action
  • When we file a probate claim
  • We have pending litigation