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2007•SSRN Electronic JournalOpen access

The Impact of Code Sec. 7491 Burden-Shifting in Tax Controversy Litigation

Megan L. Brackney

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Abstract

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.

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What this paper is about

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.

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Available abstract

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.

Key concepts: Internal revenue, Code (set theory), Revenue, Burden of proof, Tax revenue, Business, Service (business), Public economics

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