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Code of Federal Regulations (Last Updated: July 5, 2024) |
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Title 26 - Internal Revenue |
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Chapter I - Internal Revenue Service, Department of the Treasury |
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SubChapter F - Procedure and Administration |
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Part 301 - Procedure and Administration |
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SubPart - Transferees and Fiduciaries |
§ 301.6902-1 - Burden of proof.
Latest version.
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§ 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.