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26 CFR Part 301 Procedure and Administration - complete›PART 301—PROCEDURE AND ADMINISTRATION›Transferees and Fiduciaries

§ 301.6902-1 Burden of proof.

26 CFR Part 301 Procedure and Administration - complete · 2026-09-26 edition · updated 2026-10-03 · California

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.

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▸Contents — 26 CFR Part 301 Procedure and Administration - complete
26 CFR Part 301 Procedure and Administration - complete

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