What is the burden of proof when disputing the application of the increased interest rate?
MultiRegion, United States of America
The following excerpt is from Hill v. Commissioner of Internal Revenue, 204 F.3d 1214 (9th Cir. 2000):
Petitioners bear the burden of proof when disputing the application of the increased interest rate to them. See Rybak v. Commissioner, 91 T.C. 524, 567 (1988). Given the clear error standard of review, petitioners fall far below
Page 1221
the threshold for showing that the tax court erred in its factual determinations.
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