Professional Experience

Mr. Fitzgerald’s practice focuses on federal and state income taxation including transactional matters, controversies, administration and regulations, ruling requests and other tax matters.  Transactional matters include planning and advising regarding international tax matters as well as U.S. domestic matters. He performs these services for corporations, partnerships and individuals. The industry groups to which these services are rendered are diverse and include financial institutions, real estate, nonprofits and the wine industry.

Mr. Fitzgerald previously served for five years in the Office of the Chief Counsel, Internal Revenue Service, Washington, D.C.

Education

Georgetown University, LL.M., 1977.

Duke Law School, J.D., 1973.

University of North Carolina, A.B., 1967.
Phi Beta Kappa.

Memberships & Activities

Admitted to practice in California, the District of Columbia, and before the United States Tax Court.

Former adjunct professor, University of San Diego School of Law.

Publications

"Does Service’s Position on Stapled Stock Open a Loophole for Foreign Operations?” Journal of Taxation, June 1979.