It was 1.9M (not B) shares of PLUG. FiveT Capital Holding AG is Roth's holding company, so he owned his PLUG shares indirectly through FiveT Capital Holding AG, which owned the shares directly. In other words, Roth owned the shares via his holding company. If there was a capital loss in the holding company (another asset), that would offset some tax liability for sure, and he can surely list the $265K (plus other expenses) for the purchase of QUTR as a business expense to put a very small dent in his tax liability.