The Guardian reports Bates and his solicitor Mark Taylor may have breached insolvency laws by acting as directors of Leeds United Football Club Limited, the new company formed to buy the club out of administration.
It has been suggested that they did not have permission from a court to be directors.
HM Revenue and Customs believed permission is required because both men were previously directors of a different company, also called Leeds United Football Club Limited, which went into liquidation in June last year.
Part of the Insolvency Act 1986 states that anybody who has been a director of a company which has gone into liquidation must obtain the court's permission if he wants to be a director of a new company with a similar name within five years.
Trading without obtaining that permission is a criminal offence and anyone prosecuted and found guilty of it is, according to the act, liable to a fine or imprisonment.
The Guardian reveals that Bates and Taylor did not comment on the possible breach so it is not known whether they have omitted to make an application or consider that it is not necessary for them to do so.