26 C.F.R. § 301.6902-1. - § 301.6902-1 Burden of Proof.
Current as of May 27, 2026
§ 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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