Treasury Regulations (26 C.F.R.)

26 CFR § 301.6902-1 — Burden of proof.

§ 301.6902-1 Burden of proof.

In proceedings before the Tax Court the burden of proof shall be upon the Commissioner to show that a petitioner is liable as a transferee of property of a taxpayer, but not to show that the taxpayer was liable for the tax.

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Source: official text