[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6902-1]

[Page 473]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                       Transferees and Fiduciaries
 
Sec. 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.