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 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.
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