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…
THE TD BANK INSIDER “BRIBE-FOR-DATA” SCHEME (USA)
Date: February 17, 2026 Perpetrator: Edward Low (Former Bank Employee)
Case Description: In a high-profile case of “Insider Threat,” Edward Low, a former employee of TD Bank in New York, pleaded guilty in a New Jersey federal court to accepting bribes in exchange for confidential customer data. Between 2021 and 2022, Low leveraged his internal access to harvest the personal details of high-balance account holders. He then sold this “hot data” to external fraud syndicates for as little as $26,700 in personal kickbacks.
The external fraudsters used the information Low provided to conduct “Account Takeovers” (ATO), creating fraudulent checks and falsifying bank records to drain over $500,000 from unsuspecting customers. Low even went as far as helping co-conspirators open shell company accounts at a second financial institution where he was later employed. He now faces a maximum penalty of 30 years in prison. This case has sent shockwaves through the global banking sector, highlighting that even the most robust external firewalls cannot protect against a “rogue insider” with administrative credentials.
Link to Original: US Dept of Justice – TD Bank Insider Plea