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:
“America—rather, the United States—seems to me to be the Jew among the nations. It is resourceful, adaptable, maligned, envied, feared, imposed upon. It is warm-hearted, overfriendly; quick-witted, lavish, colorful; given to extravagant speech and gestures; its people are travelers and wanderers by nature, moving, shifting, restless; swarming in Fords, in ocean liners; craving entertainment; volatile. The schnuckle among the nations of the world.”
—Edna Ferber (1887–1968)
“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)
“Emblem: the carapace of the great crowned snail is painted with all the flags of the United Nations.”
—Mason Cooley (b. 1927)
“We cannot feel strongly toward the totally unlike because it is unimaginable, unrealizable; nor yet toward the wholly like because it is stale—identity must always be dull company. The power of other natures over us lies in a stimulating difference which causes excitement and opens communication, in ideas similar to our own but not identical, in states of mind attainable but not actual.”
—Charles Horton Cooley (1864–1929)