Stuart is a seasoned tax litigator with more than three decades of experience in government and private practice.

He spent nearly 30 years as a senior litigator in the Tax Division of the U.S. Department of Justice, where he led high-profile cases such as the first tax shelter promoter summons case and successful efforts to enforce “John Doe” summonses against major foreign banks. After leaving the government, he served nearly three years as editor of Tax Notes International, a leading industry publication covering global tax news and issues.  

In addition to his work on IRS summons cases, Gibson has litigated an expansive variety of civil tax disputes in courts across the United States, including matters involving individual and corporate income taxes, international tax issues, bankruptcy, ERISA, wrongful disclosure, the Freedom of Information and Privacy Acts, as well as general commercial issues including bond, contract, and lien priority matters. His experience also includes seven years at the IRS as a senior trial attorney in Boston and St. Paul, Minn.

Stuart is a noted author and speaker on tax issues at venues around the world.

  • Experience

    • Led the first foreign tax credit generator tax shelter case tried in a district court, Pritired I LLC v. U.S., 816 F.Supp.2d 693 (S.D. Iowa 2011)
    • Led high-profile “John Doe” summons cases against major foreign banks
    • Led first tax shelter promoter summons case against major accounting firm
  • Credentials

    Education

    • University of Minnesota Law School, J.D., 1976
    • Northwestern University, B.S., Journalism, Advertising, 1973

    Bar Admissions

    • District of Columbia
    • Minnesota
    • U.S. Court of Appeals for the Fifth Circuit
    • U.S. Court of Appeals for the District of Columbia Circuit
    • U.S. District Court for the District of Minnesota
    • U.S. Court of Federal Claims
    • U.S. Tax Court

      Professional Memberships

      • American Bar Association, Section on Taxation, Member

      Teaching Appointments

      • Department of Justice National Advocacy Center, Civil Trial Advocacy and Civil Pretrial Practice, Instructor
      • Tax Division Advocacy Institute, Instructor
    • Insights

      TITLE
      Article

      Value Added Tax in United Arab Emirates

      The Billionaire Chronicle

      In The News
      Alert

      Eat, Drink, and Deduct (50 Percent At Least)

      In December 2017, Congress passed major changes to the tax laws.

      In The News
      Alert

      We’re Not in South Dakota Anymore, Toto

      At first glance, one might conclude that the U.S. Supreme Court’s decision in South Dakota v. Wayfair would have an immediate impact only on those out-of-state vendors that sell goods and services into South Dakota.

      Other Publications

      • “If the IRS Needs Good Lawyers, It Should Look Across the Street,” Tax Notes Today (Mar. 30, 2015)
      • “Summonses,” Chapter 13 in IRS Practice and Procedure by Leslie Book and Michael Saltzman, 2nd ed. (rev.), Warren Gorham Lamont

      Speeches & Presentations

      • “Reforms, Repeals and Referendums: Assessing the Political Landscape in Tax,” (keynote speaker) Tax Congress for Financial Institutions, Millennium Gloucester Hotel, London, U.K. (Sep. 19, 2017)
      • Panelist, Panama Papers, 26th Economic Forum, Krynica, Poland (2016)
      • Seminar on Panama Papers, WU Graduate Tax Program, Vienna University, Vienna, Austria (2016)
      • Panel on Panama Papers, 16th Annual Automatic Exchange of Information Congress, London (2016)
      • Panel on OECD’s Base Erosion and Profit Shifting (BEPS) Project, Mazars LLC, Barcelona, Spain (2016)
      • Panel on Automatic Exchange of Financial Information, Conference on Tax Reform, Lisbon, Portugal (2014)
      • Panelist, NYU Tax Controversy Forum, New York (2009)
    • Citizenship

      Civic and Charitable Memberships

      • Served in various leadership roles at the Virginia School Boards Association including president, Stuart also served as a media spokeperson and advocate on education issues at the local, state, and national levels. He served as a member of the Fairfax County School Board from 1996-2011, where he helped lead the nation’s 10th largest school district.