What is the burden of proving the Commissioner's deficiency determination incorrect?
MultiRegion, United States of America
The following excerpt is from McConnell v. C.I.R., 990 F.2d 1258 (9th Cir. 1993):
The taxpayer bears the burden of proving the Commissioner's deficiency determination incorrect. Baxter v. Commissioner, 816 F.2d 493, 495 (9th Cir.1987). The tax court's finding regarding intent is one of fact and cannot be reversed unless clearly erroneous. Id. at 496.
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