Long-Term Capital Holdings V. United States

Long Term Capital Holdings, et al. v. United States was a court case argued before the United States District Court for the District of Connecticut that concerned a tax shelter used by Long-Term Capital Management, a failed hedge fund.

The tax shelter had been designed by Babcock & Brown for Long-Term Capital to shelter their short-term trading gains from 1997.

The case was an appeal of an Internal Revenue Service denial of the plaintiffs' claim of $106,058,228 in capital losses during the 1997 tax year, and associated penalties. After a bench trial, Judge Janet Bond Arterton ruled on August 27, 2004 that the transactions employed by Long-Term Capital Holdings did not have economic substance, and were disregarded for tax purposes.

Famous quotes containing the words united states, long-term, capital, holdings, united and/or states:

    Ethnic life in the United States has become a sort of contest like baseball in which the blacks are always the Chicago Cubs.
    Ishmael Reed (b. 1938)

    The strongest and most effective [force] in guaranteeing the long-term maintenance of ... power is not violence in all the forms deployed by the dominant to control the dominated, but consent in all the forms in which the dominated acquiesce in their own domination.
    Maurice Godelier (b. 1934)

    Many of us do not believe in capital punishment, because thus society takes from a man what society cannot give.
    Katharine Fullerton Gerould (1879–1944)

    Polarized light showed the secret architecture of bodies; and when the second-sight of the mind is opened, now one color or form or gesture, and now another, has a pungency, as if a more interior ray had been emitted, disclosing its deep holdings in the frame of things.
    Ralph Waldo Emerson (1803–1882)

    Greece is a sort of American vassal; the Netherlands is the country of American bases that grow like tulip bulbs; Cuba is the main sugar plantation of the American monopolies; Turkey is prepared to kow-tow before any United States pro-consul and Canada is the boring second fiddle in the American symphony.
    Andrei Andreyevich Gromyko (1909–1989)

    That Cabot merely landed on the uninhabitable shore of Labrador gave the English no just title to New England, or to the United States generally, any more than to Patagonia.
    Henry David Thoreau (1817–1862)