26 C.F.R. § 301.7454-1 Burden of proof in fraud and transferee cases.
Title 26 - Internal Revenue
In any proceeding involving the issue whether the petitioner has been guilty of fraud with intent to evade tax, the burden of proof in respect of such issue shall be upon the Commissioner.
Title 26: Internal Revenue
PART 301—PROCEDURE AND ADMINISTRATION
Judicial Proceedings
§ 301.7454-1 Burden of proof in fraud and transferee cases.
