§ 301.6902-1. Burden of proof.
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/us/cfr/t26/s§ 301.6902-1·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
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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§ 301.6902-1
Burden of proof.
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