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:
“What the United States does best is to understand itself. What it does worst is understand others.”
—Carlos Fuentes (b. 1928)
“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)
“As our boys and men are all expecting to be Presidents, so our girls and women must all hold themselves in readiness to preside in the White House; and in no city in the world can honest industry be more at a discount than in this capital of the government of the people.”
—Jane Grey Swisshelm (1815–1884)
“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)
“I incline to think that the people will not now sustain the policy of upholding a State Government against a rival government, by the use of the forces of the United States. If this leads to the overthrow of the de jure government in a State, the de facto government must be recognized.”
—Rutherford Birchard Hayes (1822–1893)
“So the brother in black offers to these United States the source of courage that endures, and laughter.”
—Zora Neale Hurston (1891–1960)