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:
“Madam, I may be President of the United States, but my private life is nobody’s damn business.”
—Chester A. Arthur (1829–1886)
“Attachment to a baby is a long-term process, not a single, magical moment. The opportunity for bonding at birth may be compared to falling in love—staying in love takes longer and demands more work.”
—T. Berry Brazelton (20th century)
“For mankind, speech with a capital S is especially meaningful and committing, more than the content communicated. The outcry of the newborn and the sound of the bells are fraught with mystery more than the baby’s woeful face or the venerable tower.”
—Paul Goodman (1911–1972)
“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)
“The United States is just now the oldest country in the world, there always is an oldest country and she is it, it is she who is the mother of the twentieth century civilization. She began to feel herself as it just after the Civil War. And so it is a country the right age to have been born in and the wrong age to live in.”
—Gertrude Stein (1874–1946)
“The admission of the States of Wyoming and Idaho to the Union are events full of interest and congratulation, not only to the people of those States now happily endowed with a full participation in our privileges and responsibilities, but to all our people. Another belt of States stretches from the Atlantic to the Pacific.”
—Benjamin Harrison (1833–1901)