StacksVerified U.S. federal law reference

26 CFR §301.6902-1 — -1 Burden of proof.

Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov
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.