[Code of Federal Regulations]
[Title 26, Volume 7]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.534-1]

[Page 244]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.534-1  Burden of proof as to unreasonable accumulations generally.

    For purposes of applying the presumption provided for in section 
533(a) and in determining the extent of the accumulated earnings credit 
under section 535(c)(1), the burden of proof with respect to an 
allegation by the Commissioner that all or any part of the earnings and 
profits of the corporation have been permitted to accumulate beyond the 
reasonable needs of the business may vary under section 534 as between 
litigation in the Tax Court and that in any other court. In case of a 
proceeding in a court other than the Tax Court, see paragraph (b) of 
Sec. 1.533-1.