PRACTICE AREAS & Administration

JOHN F. DEAN PROFESSOR OF TAX LITIGATION AND U.S. TAX COURT TRIAL PRACTICE

Michael Stuart is a veteran observer of United States Tax Court litigation and trial practice. He continues to learn from the judges who preside, legal scholars who research and write, and the practitioners to whom he defers - they teach him more about everyday tax practice than anyone. His strategic approach to successful courtroom practice has been utilized by bar-admitted federally-authorized tax practitioners in the U.S. Tax Court throughout the national jurisdiction. As a legal educator focused on the Federal judicial tax forum, he works closely with various FATPs and judicial officers, including Tax Court judges, federal tax scholars, law professors and legal authors, IRS enrolled agents, tax attorneys, CPAs, PhDs and other members of the Tax Court Bar and academic community, all of whom provide exceptional counsel, advice, criticism, and support. But he believes that the greatest contributions come from the bar applicants themselves. He is co-author and editor of the Guide to Admission and Practice in U.S. Tax Court, with contributions from former U.S. Tax Court Judge John F. Dean, Professor Joni Larson, Professor James H. Chapman, Professor L.B. Carpenter and others.

IRS-United States Tax Court Bar Education  & University of Alabama Contributions

Ten years ago, Professor Stuart negotiated and formed a four-year collaborative between the Tax Law Institute and the University of Alabama School of Law Graduate Tax Program. He chaired the joint program that granted open admissions to IRS enrolled agents to earn the Certificate in Tax Law (defunct) and prepared LL.M. students for trial practice in Tax Court. The year before, he persuaded a then-retiring United States Tax Court judge to provide judicial oversight for the legal education of non-lawyers training as United States Tax Court Practitioners. The judge, the Honorable John F. Dean, left the bench in 2014 and joined the Tax Law Institute as Distinguished Judicial Speaker. He lectured for three testing cycles (6 years), providing legal instruction to non-attorney bar applicants. Judge Dean team-taught tax evidence, litigation and trial practice with the eminent legal scholar and author, Joni Larson, who as the Distinguished Visiting Professor contributed for two years at the Tax Law Institute. Judge Dean was named the first Dean of the Faculty at the Tax Law Institute in 2021 when the organization moved to its current Washington DC headquarters. He is presently Dean Emeritus and is fully retired.

Post-Wall Street Years

Immediately after completing his J.D., Michael Stuart re-entered public service in 2001 as an unpaid legal intern. Supervised by the head of the Bankruptcy Unit of the Consumer Division at the New York Legal Aid Society, he acted as liaison between the IRS and indigent clients, until  the September 11th attacks temporarily closed the Church Street offices located in the shadow of the World Trade Center. Prior to attending law school, he trained in international business and financial management at the Fletcher School of Law and Diplomacy (Tufts) and earned a master's degree in public administration (international relations) from Harvard (Kennedy School of Government) in 1984 as well as a certificate in elementary Mandarin Chinese. He was trained in the use of global derivatives at Morgan Stanley in New York and certified in political economy at the Henry George Institute of Economics. Before he entered Harvard, he served as interim aide to and courier for the North American Secretary at the Trilateral Commission and  as aide to and member of the advance team of John V. Lindsay's U.S. Senatorial  Campaign in New York. From 1978 through 1998, he maintained a small office at 80 Wall Street in New York's Financial District from where he planned, financed and developed $45 million of affordable housing in NYC, at the height of the homeless crisis. During the interim, he  worked with local banks, a parish church, the New York State Harlem Urban Development Corporation and New York City's Housing Preservation Department (HPD) to rehabilitate distressed apartment buildings then-recently removed from the City's 7A Program and situated on Manhattan's Morningside Heights at Columbia University, East Harlem and the Lower Eastside. He also was active as a housing developer in West Harlem. After years of frustration in an attempt to restore historic brownstones surrounding the national landmark, Hamilton Grange, home and land estate of a Founding Father, Alexander Hamilton, he was invited to Yale's architecture school where he became a proponent for historic preservation and environmental design (Class of '87). Several years later, as an environmental advocate, he challenged and lost to the incumbent for a New York State Senate seat in 1991. After his unsuccessful state senatorial bid, he was ushered into mainstream Washington DC politics and became a special executive assistant to the ranking minority member of the National Executive Committee of the RNC. He was seated on the Domestic Policy Advisory Committee where he advocated for the use of more tax dollars to stimulate economic development in poorer communities. He advised the White House and wrote a position paper for President George H.W. Bush where he spoke to needed changes in tax policy to encourage such endeavors. 

Post-White House Years

After his White House advisory ended, he was appointed visiting scholar of public policy (taxation) at Yale Law School (1993). He also was named to the NYC mayoral transition team, where he became an unsuccessful candidate for NYC Environmental Commissioner. The municipal vetting led to his selection and placement as Executive Director of the Wildlife Trust, where as the senior development officer he was charged to finance and protect the habitat of the mountain gorilla in Uganda and the rainforest of Brazil. The following year, 1994, he returned to Harvard to prepare to enter the doctoral program in public administration. Denied a candidacy, he ended his studies after one semester and went to work for the Boston affordable housing development agency as a special assistant to its director. The Center for Middle Eastern Studies then outreached and retained him in 1995 as special consultant to help launch the Saudi Royal Family-funded Harvard Islamic Banking and Finance Information Program aka Harvard Finance Project (HFP). He facilitated the collaboration with faculty at the Harvard Law School Islamic Legal Studies Program and Harvard Business School Islamic Finance Program. He also assisted the director, served as a senior researcher, manager and writer and helped to compile the world's first Islamic financial database, over one and half years. He also helped organized the First Harvard Islamic Finance Forum, where he met the president of a Washington DC-Maryland bank, Enterprise Bancorp, who commissioned him to create the Islamic banking windows at all its branches from 1997-1998. The year before, he also enrolled in law school.

Post-Harvard-Yale-British-American-Cambridge Years

After 5 years of full- and part-time study, Michael Stuart completed his course requirements in Fall 2000 and received his law school diploma, cum laude, in January 2001.  Several months later, he was appointed tenured professor of law (Islamic banking law and Shari'ah law) in August 2001, under the aegis of the BAU-University of Cambridge partnership (UK) (Cambridge University program in English Common Law). Elevated to Academic Dean of Faculty in his second year, he undertook a significant academic endeavor and founded the Islamic Law Institute to educate Western bankers on basic tenets of Shari'ah law and the principles of Islamic finance. In 2002, he was invited to lecturer on Islamic banking law at the Southern New England School of Law (rechartered as the University of Massachusetts School of Law). As he gained seniority and notoriety within the British-American-Cambridge University community, he began building an independent international tax advisory, which he delivered electronically to select clients throughout the U.S.  Over time, his interest in the advisory waned as he began to focus on U.S. domestic tax matters and United States Tax Court litigation. He established the Tax Law Institute to support his new-found interests. Professor Stuart separated from the British-American-Cambridge partnership, with ownership rights to the Tax Law Institute and became an entrepreneur. He exploited the then-still developing, technological phenomena known as the Internet and became an early proponent of digital legal education.

Most Recent Events

Then until now, Professor Stuart has operated the Tax Law Institute as an Internet education business, with a focus on teaching federal tax litigation to FATPs. Several law schools initiated programs to integrate TLI educational model into their curricula but to-date TLI has remained independent. Besides litigation, Professor Stuart has taught tax evidence, legal writing, ethics and case strategies. TLI was approved as a continuing professional education provider by the U.S. Treasury Department Internal Revenue Service in 2012. In 2019, Professor Stuart initiated TLI's charitable giving program and  founded the Hawai'i Federal Tax Clinic on the island of O'ahu. TLI has since expanded its charitable contributions to include sponsorship of an elder recipient in a joint collaborative with Harvard Medical School HMX Program. In 2024, the Hawai'i Federal Tax Clinic was approved to participate in the United States Tax Court Clinical, Student Practice and Calendar Call Program. Also, the John F. Dean Professorship was endowed by the Tax Law Institute to honor a distinguished lawyer appointed to the judiciary of the United States Tax Court and Distinguished Judicial Speaker at the Tax Law Institute. Presently, Professor Stuart serves in that role and as the educational coordinator for the free tax clinic's Pro Bono Program, where he contributes to discussions related to tax controversies and  provides case management for low-income clients with actions before the IRS Independent Office of Appeals and U.S. Tax Court. He also continues to work to find new ways to utilize A.I. to improve the remote delivery of educational services to aspiring and newly-admitted United States Tax Court Practitioners. The Tax Law Institute awards scholarships in the various disciplines of tax practice. It also retains interns who are awarded stipends to work with Teaching Faculty. Through TLI, Professor Stuart  recently approved sponsorship of an intern for technical training in A.I. at the MIT Sloan School, in furtherance of the company's charitable giving endeavors.