| Long-Term Capital Holdings v. United States | |
| Court: | United States District Court for the District of Connecticut |
| Full Name: | Long-Term Capital Holdings, et al. v. United States of America |
| Docket: | 3:01-cv-01290 3:01-cv-01291 3:01-cv-01711 3:01-cv-01713 3:01-cv-01714 |
| Citations: | 330 F. Supp. 2d 122 |
| Judge: | Janet 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]