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Long-Term Capital Holdings v. United States

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Long-Term Capital Holdings v. United States
CourtUnited States District Court for the District of Connecticut
Full case name Long-Term Capital Holdings, et al. v. United States of America
DecidedAugust 27, 2004 (2004-08-27)
Docket nos.3:01-cv-01290
3:01-cv-01291
3:01-cv-01711
3:01-cv-01713
3:01-cv-01714
Citation330 F. Supp. 2d 122
Court membership
Judge sittingJanet Bond Arterton
Keywords
Tax shelter

Long Term Capital Holdings v. United States, 330 F. Supp. 2d 122 (D. Conn. 2004), 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.[1]

The tax shelter had been designed by Babcock & Brown for Long-Term Capital to shelter its 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 so were disregarded for tax purposes.[1]

References

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  1. ^ a b Long Term Capital Holdings v. United States, 330 F. Supp. 2d 122 (D. Conn. 2004).
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