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Martin Schainbaum, JD, LL. But in 2001 the IRS made a mistake and released its tax lien. The agency has different ways to calculate the CSED, especially when the taxpayer either did not pay taxes in full or paid only partial for several years. Today, circular priority situations generally arise in lien priority disputes with secured creditors under the UCC. For example, a UCC security interest on the inventory of a corporation with a principal executive office in California, which was incorporated in Delaware, would be filed in Delaware. Ten years under state lien statute of limitations. Typically only an irs lien notices of limitations limits on collection statute expiration dates vary by state tax obligations but want to have?