Treasury Regulations · 26 CFR
§ 301.7454-1. Burden of proof in fraud and transferee cases.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 7454
Cite as 26 CFR § 301.7454-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Source
- 32 FR 15241, Nov. 3, 1967, unless otherwise noted.
- Issued under
- 26 U.S.C. § 7454
- Length
- 33 words · about 1 min to read
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.
Where it sits in 26 CFR
- Subchapter F Procedure and administration
- Part 301 Procedure and administration
- Subpart ECFR94f366dd75fae71 Judicial Proceedings
- Civil Actions by the United States
Nearby sections
- § 301.7432-1 Civil cause of action for failure to release a lien.
- § 301.7433-1 Civil cause of action for certain unauthorized collection actions.
- § 301.7433-2 Civil cause of action for violation of section 362 or 524 of the Bankruptcy Code.
- § 301.7452-1 Representation of parties.
- § 301.7454-1 Burden of proof in fraud and transferee cases.
- § 301.7454-2 Burden of proof in foundation manager, etc. cases.
- § 301.7456-1 Administration of oaths and procurement of testimony; production of records of foreign corporations, foreign trusts or estates and nonresident alien individuals.
- § 301.7457-1 Witness fees.
- § 301.7458-1 Hearings.