District Court, D. Connecticut August 27, 2004, Civil 3:01CV1290, 3:01CV1291, 3:01CV1291, 3:01CV1711, 3:01CV1713, 3:01CV1714 (JBA) (Long Term Capital Holdings v. United States)

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United States · · · 27-08-2004

FINDINGS AND OPINION

ARTERTON, District Judge.

Table of Contents

I. Summary 127

II. Factual Background 128

A. Long Term Entities 128

*126

B. Babcock and Brown (“B & B”) and Onslow Trading and Commercial LLC (“OTC”) .131

C. CHIPS and TRIPS Transactions.132

1. CHIPS IVA and IVB .132

2. TRIPS I .135

3. Purported Tax Consequences of CHIPS IVA and IVB and TRIPS 1.135

D. OTC and Long Term.136

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