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.

[Adopted by T.D. 6246, 22 FR, Aug. 1957. Revised at 32 FR 15241, Nov. 3, 1967.]