Abstract

http://ssrn.com/abstract=661601
 


 



Understanding Long Term Capital


Alvin C. Warren Jr.


Harvard Law School


Tax Notes, Vol. 106, No. 6, February 7, 2005

Abstract:     
This article examines the recent district court decision in Long Term Capital Holdings v. United States, which involved the cloning of an artificial loss that was sold to two different groups of taxpayers for deduction. Professor Warren explains the convoluted transaction and then analyzes the court's decision in favor of the government. Particularly noteworthy, he says, is the court's refusal to let the taxpayers escape penalties on the grounds that they obtained favorable legal opinions from major law firms, when those opinions were, in the court's view, superficial at best. Given the sums of money involved, Warren concludes that such dubious behavior by taxpayers and their professional advisers will change only if the federal courts are willing to sustain penalties in cases such as this.

Accepted Paper Series


Not Available For Download

Date posted: February 4, 2005  

Suggested Citation

Warren, Alvin C., Understanding Long Term Capital. Tax Notes, Vol. 106, No. 6, February 7, 2005. Available at SSRN: http://ssrn.com/abstract=661601

Contact Information

Alvin C. Warren Jr. (Contact Author)
Harvard Law School ( email )
1575 Massachusetts
Hauser Hall 308
Cambridge, MA 02138
United States
Feedback to SSRN


Paper statistics
Abstract Views: 941

© 2014 Social Science Electronic Publishing, Inc. All Rights Reserved.  FAQ   Terms of Use   Privacy Policy   Copyright   Contact Us
This page was processed by apollo3 in 0.515 seconds