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TREASURY REGULATIONS


Index  » Subchapter F  » Reg. 301.6902-1

Reg. 301.6902-1
Burden of proof

January 14, 2024


§ 301.6901-1 « Browse » § 301.6903-1

See related I.R.C. 6902

Treas. Reg. § 301.6902-1.  Burden of proof

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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