Regulations last checked for updates: Feb 15, 2026

Title 26 - Internal Revenue last revised: Feb 11, 2026
§ 301.7454-1 - Burden of proof in fraud and transferee cases.

In any proceeding involving the issue whether the petitioner has been guilty of fraud with intent to evade tax, the burden of proof in respect of such issue shall be upon the Commissioner.

authority: 26 U.S.C. 7805.
source: 32 FR 15241, Nov. 3, 1967, unless otherwise noted.
cite as: 26 CFR 301.7454-1