This case is a generalization of the facts and arguments inherent in the economic substance and holding penalty judgment of the district court in Long-Term Capital Holdings v. United States. The court upheld the IRS assertion that the deal between long-term and prospective investors no economic substance and should be taken into account for purposes of U.S. income tax purposes. The effect was to deny partnership networks, long-term capital loss of $ 106 million. The court also imposed a $ 16 million fine for gross inaccuracies. "Hide
by Henry B. Reiling, Kevin F. Wall 11 pages. Publication Date: December 2, 2004. Prod. #: 205054-PDF-ENG
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