View all text of Subpart 0-i 11 [§ 301.6901-1 - § 301.6905-1]

§ 301.6902-1 - Burden of proof.

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.