For tax professionals representing partnerships in complex examinations, particularly those involving syndicated conservation easements under the centralized partnership audit regime (BBA), the procedural safeguards surrounding the statute of limitations are paramount. The recent stipulated decision in Agate Holdings, LLC v. Commissioner, Docket No. 1464-24, provides a critical examination of the final partnership adjustment (FPA) limitations period under I.R.C. § 6235, the mechanics of modification period extensions via Form 8984, and the high evidentiary burden the IRS faces when attempting to assert the civil fraud penalty under I.R.C. § 6663 to keep an expired assessment statute open.
This article details the facts of the case, the taxpayer’s motion for summary judgment, the troubling IRS actions that necessitated the taxpayer’s defense, and the Tax Court’s ultimate…
This remains the most prevalent form of financial crime globally. It targets the direct access points to your money: your cards and your bank accounts.
- Skimming: Criminals use small devices called “skimmers” placed over ATM or point-of-sale card slots to capture the data from your card’s magnetic strip.
- Card-Not-Present (CNP) Fraud: This occurs during online shopping where a physical card isn’t required. Thieves use stolen card numbers, expiry dates, and CVV codes to make unauthorized purchases.
- Account Takeover (ATO): A hacker gains access to your online banking credentials (often through malware or phishing) and changes the contact details or passwords, locking you out while they drain your funds.