Long-Term Capital Holdings v. United States

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]

Long-Term Capital Holdings v. United States
Court	United States District Court for the District of Connecticut
Full case name	Long-Term Capital Holdings, et al. v. United States of America
Decided	August 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
Citation	330 F. Supp. 2d 122
Court membership
Judge sitting	Janet Bond Arterton
Keywords
Tax shelter

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]