Bill Gates v. United States

Bill Gates appeals from the district court’s order granting summary judgment against him in his suit contesting a $69,000 penalty assessed against him by the Internal Revenue Service (IRS) for promoting abusive tax shelters, 694 F.Supp. 610. On appeal Gates challenges the district court’s determination of liability and its assessment of penalties. We affirm on the issue of liability and reverse as to the assessment of penalties.

In 1982 and 1983 Gates became involved with the promotion of two tax shelter schemes established by H & L Schwartz, Inc. (Schwartz, Inc.). Gates encouraged people to…