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Sunday, August 29, 2004

IRS Wins Long-Term Capital Management Case

Sunday, August 29, 2004

On Friday, the U.S. District Court for the Distirct of Connecticut issed a 198-page opinion in favor of the IRS in the infamous Long-Term Capital Management case. The court found that LTCM improperly took $106 million in tax deductions, resulting in perhaps the IRS's largest civil tax victory ($56 million in taxes and penalties). The court held that the nine cross-border lease-stripping transactions lacked economic substance and was sharply critical of LTCM's tax lawyers (William McKee and Mark Kuller, formerly of King & Spalding (Atlanta) and later founders of the McKee Kuller law firm). For the New York Times coverage, see here.

http://taxprof.typepad.com/taxprof_blog/2004/08/irs_wins_longte.html

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Please post any comments on the possible implications for the upcoming Black & Decker tax case of the Long Term Capital holding

Posted by: Jack Smith | Sep 1, 2004 8:51:33 AM