# Treas. Reg. § 301.6902-1: Burden of proof.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-301.6902-1>. Interprets 26 U.S.C. § 6902.

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.