Mass. Gen. Laws » Part I Title IX Chapter 62C
Massachusetts General Laws

Mass. Gen. Laws ch. 62C, § 65 (2026)

Time for collection of taxes; bankruptcy cases

✓ current as of July 2026
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Section 65. Taxes shall be collected: (i) within 10 years after the assessment of the tax; (ii) within any further period after that 10–year period during which the taxes remain unpaid but only against any real or personal property of the taxpayer to which a tax lien has attached and for which a notice of lien has been filed or recorded under section 50 in favor of the commonwealth in accordance with applicable state or federal law within 10 years after the assessment of the tax; (iii) before the expiration of any period of collection agreed upon in writing by the commissioner and the taxpayer before the expiration of that 10–year period; or (iv) if there is a release of levy under section 64 after that 10–year period, then before that release. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon. When any question relative to such taxes is pending before any agency or court at the end of that 10–year period, the commissioner's right to collect any tax due shall continue until 1 year after the final determination of that question.

For bankruptcy cases under relevant chapters of Title 11 of the United States Code, the running of the period of limitations in this section on collections shall be suspended for the period during which the commissioner is prohibited by reason of such case from collecting the tax, and for the period during which a plan for payment of the tax is in effect, and for six months thereafter.

The running of the period of limitations in this section on collections shall be suspended for the period during which the payment or collection of the tax is stayed pursuant to subsection (e) of section 32.

Notes of Decisions
Cited in 6 cases, 1989–2010 · leading case: Drake v. Massachusetts Dep't of Revenue (In Re Drake), 434 B.R. 11 (Bankr. D. Mass. 2010).
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Drake v. Massachusetts Dep't of Revenue (In Re Drake), 434 B.R. 11 (Bankr. D. Mass. 2010). · cites it 3× “Drake argues that this prevents the MDOR from asserting that it was prohibited from collecting on account of that debt within the meaning of the tolling provision of Mass. Gen. Laws ch. 62C, § 65. Even if that were true, the statute of limitations remained tolled pursuant to the…”
Luchini v. Comm'r of Revenue, 436 Mass. 403 (Mass. 2002). “As for the remainder owed, G. L. c. 62C, § 65, provides that taxes shall be collected within six years after their assessment, but that “[wjhen any question relative to such taxes is pending before any agency or court at the end of such six-year period, the [Cjommissioner’s…”
Dep't of Revenue v. Shea, 885 N.E.2d 866 (Mass. App. Ct. 2008). · cites it 8× “On August 10, 1998, 108 days after denial of the application for further review, the Sheas submitted to the DOR an “Offer in Settlement” (Offer) of the outstanding tax liability, and agreed with the DOR that the statute of limitations embodied in G. L. c. 62C, § 65, 3 would be…”
In re Vallis, 97 B.R. 124 (D. Mass. 1989). · cites it 4× “Mass. Gen.Laws Ann. ch. 62C, § 65 (originally added by 1976 Mass.”
Luchini v. Adams, 11 Mass. L. Rptr. 742 (Mass. Super. Ct. 2000). · cites it 2× “*745 Regarding the remainder of the monies owed by the plaintiff, G.L.c. 62C, §65 states that taxes shall be collected within six years after the assessment of the tax.”
Materials Dev. Corp. v. Comm'r of Revenue, 780 N.E.2d 87 (Mass. App. Ct. 2002). “The statute of limitations in question is G. L. c. 62C, § 65, which, as amended by St.”
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