The Impact of Code Sec. 7491 Burden-Shifting in Tax Controversy Litigation
11 Pages Posted: 15 Nov 2015
Date Written: August 1, 2007
Internal Revenue Code ("IRC") § 7491 shifts the burden of proof from the taxpayers to the Internal Revenue Service where certain requirements are met. This article discusses those requirements, as well as the impact of IRC § 7491 in civil tax cases.
Suggested Citation: Suggested Citation