Implements § 6902Open in workspace
Reg. § 301.6902-1 Burden of proof.
26 CFR § 301.6902-1eCFR, current through 2026-07-14
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.