26 C.F.R. § 301.6902-1

Current through September 30, 2024

Section 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.

26 C.F.R. §301.6902-1