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Transferees and Fiduciaries

§ 301.6902-1 Burden of proof.

26 C.F.R. Part 301 — Procedure And Administration · 2026 edition · updated 2026-10-04 · United States

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 C.F.R. Part 301 — Procedure And Administration
26 C.F.R. Part 301 — Procedure And Administration

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