26 C.F.R. § 301.6902-1

Burden of proof.

Last amended: 2016Year: 2026Length: 42 wordsOfficial source

Cite as 26 C.F.R. § 301.6902-1 (2026)

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: Burden of proof. | Justis AI