26 C.F.R. § 301.6902-1 Burden of proof.
Title 26 - Internal Revenue
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.
Title 26: Internal Revenue
PART 301—PROCEDURE AND ADMINISTRATION
Transferees and Fiduciaries
§ 301.6902-1 Burden of proof.
