26 CFR § 301.6902-1 - Burden of proof.

---
identifier: "/us/cfr/t26/s301.6902-1"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 301.6902-1 - Burden of proof."
title_number: 26
title_name: "Internal Revenue"
section_number: "301.6902-1"
section_name: "Burden of proof."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "F"
subchapter_name: "PROCEDURE AND ADMINISTRATION"
part_number: "301"
part_name: "PROCEDURE AND ADMINISTRATION"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805."
regulatory_source: "32 FR 15241, Nov. 3, 1967, unless otherwise noted."
cfr_part: "301"
---


# 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.