This case summarizes the knowledge and reasoning resulting from the economic substance and impose punishment stocks of the district court decision in Long Term Capital Holdings v. United States. The court upheld the IRS’s assertion that a transaction between long-term investor and a supposed missing and must be taken into account for U.S. income tax economic substance. The effect was to deny the partnership a net long-term capital growth loss of $ 106 million. The court imposed $ 16 million pena … Read more »

This case summarizes the knowledge and reasoning resulting from the economic substance and impose punishment stocks of the district court decision in Long Term Capital Holdings v. United States. The court upheld the IRS’s assertion that a transaction between long-term investor and a supposed missing and must be taken into account for U.S. income tax economic substance. The effect was to deny the partnership a net long-term capital growth loss of $ 106 million. The court imposed fines of $ 16 million for gross inaccuracy.
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from
Henry B. Reiling,
Kevin F. Wall
11 pages.
Release Date: 02 Dec, 2004. Prod #: 205054-PDF-ENG
LTCM profit HBR case solution

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