StacksVerified U.S. regulatory reference

26 U.S.C. § 7427

Verified against govinfo.gov as of June 20, 2026View official text on govinfo.gov
In any proceeding involving the issue of whether or not a tax return preparer has willfully attempted in any manner to understate the liability for tax (within the meaning of section 6694(b)), the burden of proof in respect to such issue shall be upon the Secretary.