United States v. Gerald L. Schulman

TANG, Circuit Judge:

The government appeals the district court’s dismissal of 23 counts of a 25-count indictment charging Schulman with conspiracy, tax fraud and perjury. The charges arose from the promotion, sale and administration of a tax shelter scheme Schulman developed, in which 91 limited partnerships purchased buildings leased to the United States Postal Service, public utilities and state governmental units, and claimed interest deductions equal to each limited partner’s total capital contribution. The district court dismissed the conspiracy and tax fraud charges on the ground that…