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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. 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. References External links *A Tax Shelter, Deconstructed a ''New York Times ''The New York Times'' (''NYT'') is an American daily newspaper based in New York City. ''The New York Times'' covers domestic, ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States District Court For The District Of Connecticut
The United States District Court for the District of Connecticut (in case citations, D. Conn.) is the federal district court whose jurisdiction is the state of Connecticut. The court has offices in Bridgeport, Hartford, and New Haven. Appeals from the court are heard by the United States Court of Appeals for the Second Circuit. It was one of the original 13 courts established by the Judiciary Act of 1789, 1 Stat. 73, on September 24, 1789.U.S. District Courts of Connecticut, Legislative history '' Federal Judicial Center''. The Court initially had a single judge, and remained so composed until March 3, 1927, when a second judge was added by 1927 44 Stat. 1348. [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Plaintiff
A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of the plaintiff and make the appropriate court order (e.g., an order for damages). Plaintiff is the term used in civil cases in most English-speaking jurisdictions, the notable exceptions being England and Wales, where a plaintiff has, since the introduction of the Civil Procedure Rules in 1999, been known as a "claimant" and Scotland, where the party has always been known as the "pursuer". In criminal cases, the prosecutor brings the case against the defendant, but the key complaining party is often called the "complainant". In some jurisdictions, a lawsuit is commenced by filing a summons, claim form or a complaint. These documents are known as pleadings, that set forth the alleged wrongs committed by the defendant or defendants with a d ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
2004 In United States Case Law
4 (four) is a number, numeral and digit. It is the natural number following 3 and preceding 5. It is a square number, the smallest semiprime and composite number, and is considered unlucky in many East Asian cultures. Evolution of the Hindu-Arabic digit Brahmic numerals represented 1, 2, and 3 with as many lines. 4 was simplified by joining its four lines into a cross that looks like the modern plus sign. The Shunga would add a horizontal line on top of the digit, and the Kshatrapa and Pallava evolved the digit to a point where the speed of writing was a secondary concern. The Arabs' 4 still had the early concept of the cross, but for the sake of efficiency, was made in one stroke by connecting the "western" end to the "northern" end; the "eastern" end was finished off with a curve. The Europeans dropped the finishing curve and gradually made the digit less cursive, ending up with a digit very close to the original Brahmin cross. While the shape of the character f ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Taxation And Revenue Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film * ''The United'' (film), an unreleased Arabic-language film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe * "United (Who We Are)", a song by XO-IQ, featured in the television ser ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
New York Times
''The New York Times'' (''NYT'') is an American daily newspaper based in New York City. ''The New York Times'' covers domestic, national, and international news, and publishes opinion pieces, investigative reports, and reviews. As one of the longest-running newspapers in the United States, the ''Times'' serves as one of the country's Newspaper of record, newspapers of record. , ''The New York Times'' had 9.13 million total and 8.83 million online subscribers, both by significant margins the List of newspapers in the United States, highest numbers for any newspaper in the United States; the total also included 296,330 print subscribers, making the ''Times'' the second-largest newspaper by print circulation in the United States, following ''The Wall Street Journal'', also based in New York City. ''The New York Times'' is published by the New York Times Company; since 1896, the company has been chaired by the Ochs-Sulzberger family, whose current chairman and the paper's publ ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Economic Substance
Economic substance is a doctrine in the tax law of the United States under which a transaction must have both a substantial purpose aside from reduction of tax liability and an economic effect aside from the tax effect in order to qualify for any tax benefits. This doctrine is used by the Internal Revenue Service to determine whether tax shelters, or strategies used to reduce tax liability, are considered "abusive". Under the doctrine, for a transaction to be respected, the transaction must change the taxpayer's economic position in a "meaningful way" apart from the Federal income tax effects, and the taxpayer must have had a "substantial purpose" for entering into the transaction, apart from the Federal income tax effects. The economic substance doctrine was originally a common law doctrine. The doctrine was codified in subsection (o) of section 7701 of the Internal Revenue Code by the Health Care and Education Reconciliation Act of 2010.Sec. 1409, Pub. L. No. 111-152, 124 Stat. 1 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Bench Trial
A bench trial is a trial by judge, as opposed to a jury. The term applies most appropriately to any administrative hearing in relation to a summary offense to distinguish the type of trial. Many legal systems ( Roman, Islamic) use bench trials for most or all cases or for certain types of cases. As a jury renders a verdict, in a bench trial, a judge does the same by making a finding. United Kingdom England and Wales Most civil trials proceed without a jury and are heard by a judge sitting alone. Summary criminal trials may be heard by a single district judge ( magistrates' court) or by a panel of at least two, but more usually three, magistrates. Section 47 of the Criminal Justice Act 2003 allows a bench trial for indictable offences, but is rarely used, having been exercised only two times since its inception. Scotland Most civil trials in Scotland are conducted in a sheriff court by a sheriff sitting alone. In the Court of Session, a judge in either the outer or inne ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Year
A fiscal year (also known as a financial year, or sometimes budget year) is used in government accounting, which varies between countries, and for budget purposes. It is also used for financial reporting by businesses and other organizations. Laws in many jurisdictions require company financial reports to be prepared and published on an annual basis but generally with the reporting period not aligning with the calendar year (1 January to 31 December). Taxation laws generally require accounting records to be maintained and taxes calculated on an annual basis, which usually corresponds to the fiscal year used for government purposes. The calculation of tax on an annual basis is especially relevant for direct taxes, such as income tax. Many annual government fees—such as council tax and license fees are also levied on a fiscal year basis, but others are charged on an anniversary basis. Some companies, such as Cisco Systems, end their fiscal year on the same day of the week each ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Capital Loss
Capital loss is the difference between a lower selling price and a higher purchase price or cost price of an eligible Capital asset, which typically represents a financial loss for the seller. This is distinct from losses from selling goods below cost, which is typically considered loss in business income. United States The IRS states that "If your capital losses exceed your capital gains, the excess can be deducted on your tax return." Limits on such deductions apply. For individuals, a net loss can be claimed as a tax deduction against ordinary income, up to $3,000 per year ($1,500 in the case of a married individual filing separately). Any remaining net loss can be carried over and applied against gains in future years. However, losses from the sale of personal property, including a residence, do not qualify for this treatment. Special wash sale rules apply if the same or substantially similar asset In financial accounting, an asset is any resource owned or controlled by ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the Federal government of the United States, United States federal government, which is responsible for collecting Taxation in the United States, U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the United States Department of the Treasury, Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure funded over a fifth of the Union's war expens ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Federal Supplement
The ''Federal Supplement'' () is a case law reporter (law), reporter published by West Publishing in the United States that includes select court decision, opinions of the United States district courts since 1932, and is part of the National Reporter System. Although the ''Federal Supplement'' is an unofficial reporter and West is a private company that does not have a legal monopoly over the court opinions it publishes, it has so dominated the industry in the U.S. that legal professionals uniformly case citation, cite the ''Federal Supplement'' for included decisions. Approximately 40 new volumes are published per year. Distinctions Before 1932, federal district court cases were published in the ''Federal Reporter'', which now publishes only case law from the United States Courts of Appeals and the United States Court of Federal Claims; prior series had varying scopes that covered opinions of other federal courts as well. The ''United States Reports'' are the official law r ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Appeal (law)
In law, an appeal is the process in which cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and interpreting law. Although appellate courts have existed for thousands of years, common law countries did not incorporate an affirmative right to appeal into their jurisprudence until the 19th century. Terminology American English and British English have diverged significantly on the topic of appellate terminology. American cases go up "on appeal" and one "appeals from" ( intransitive) or "appeals" ( transitive) an order, award, judgment, or conviction, while decisions of British courts are said to be "under appeal" and one "appeals against" a judgment. An American court disposes of an appeal with words like "judgment affirmed" (the appeal is without merit) or "judgment reversed" (the appeal has merit), while a British court dispose ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
