26 C.F.R. § 301.7454-1. - § 301.7454-1 Burden of Proof in Fraud and Transferee Cases.

Current as of May 27, 2026

Section 301.7454-1 - § 301.7454-1 Burden of Proof in Fraud and Transferee Cases.Section 301.7454-1 - § 301.7454-1 Burden of Proof in Fraud and Transferee Cases.

Section 301.7452-1 - § 301.7452-1 Representation of Parties.Section 301.7454-2 - § 301.7454-2 Burden of Proof in Foundation Manager, Etc. Cases.

§ 301.7454-1 Burden of proof in fraud and transferee cases.

In any proceeding involving the issue whether the petitioner has been guilty of fraud with intent to evade tax, the burden of proof in respect of such issue shall be upon the Commissioner.

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