Regulations last checked for updates: Oct 17, 2024

Title 26 - Internal Revenue last revised: Oct 10, 2024
§ 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.

authority: Section 301.1474-1 also issued under 26 U.S.C. 1474(f)
source: 32 FR 15241, Nov. 3, 1967, unless otherwise noted.
cite as: 26 CFR 301.6902-1