StacksVerified U.S. regulatory reference

26 CFR §301.6902-1

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.