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.
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Don’t join too many gangs. Join few if any.
Join the United States and join the family
But not much in between unless a college.”
—Robert Frost (1874–1963)
“Whether changes in the sibling relationship during adolescence create long-term rifts that spill over into adulthood depends upon the ability of brothers and sisters to constantly redefine their connection. Siblings either learn to accept one another as independent individuals with their own sets of values and behaviors or cling to the shadow of the brother and sister they once knew.”
—Jane Mersky Leder (20th century)
“Capital is money, capital is commodities.... By virtue of it being value, it has acquired the occult ability to add value to itself. It brings forth living offspring, or, at the least, lays golden eggs.”
—Karl Marx (1818–1883)
“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)
“Yesterday, December 7, 1941Ma date that will live in infamy—the United States of America was suddenly and deliberately attacked by naval and air forces of the Empire of Japan.”
—Franklin D. Roosevelt (1882–1945)
“... there is a place in the United States for the Negro. They are real American citizens, and at home. They have fought and bled and died, like men, to make this country what it is. And if they have got to suffer and die, and be lynched, and tortured, and burned at the stake, I say they are at home.”
—Amanda Berry Smith (1837–1915)