26 C.F.R. § 301.7454-1

Burden of proof in fraud and transferee cases.

Last amended: 2016Year: 2026Length: 33 wordsOfficial source

Cite as 26 C.F.R. § 301.7454-1 (2026)

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.
26 C.F.R. § 301.7454-1: Burden of proof in fraud and transferee cases. | Justis AI