{"id":"LAW-038","kind":"law","level":"law","jurisdiction":"","state":"","metro":"","industry":"","agency":"","eco":"","issuer":"Office of the Law Revision Counsel","authority":"26 U.S.C. 7454 (OLRC current)","instrument":"26 U.S.C. 7454 (OLRC current)","title":"26 U.S.C. 7454 (OLRC current)","dateIssued":"2026-09-26","effective":"","end":"","startDate":"2026-09-26","endDate":"","quarters":[],"types":[],"addressees":[],"clause":"(a) Fraud. 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 Secretary. (sec. 7454(a))... In any case involving the issue of fraud with intent to evade tax, the burden of proof in respect of that issue is on the respondent, and that burden of proof is to be carried by clear and convincing evidence. See Code sec. 7454(a). (Tax Ct. R. 142(b), verified Sept. 15, 2026 from the Tax Court\u0027s rule text)","enforcement":"","functions":[],"notes":"Re-rendered locally from the OLRC HTML on 2026-09-26 so that the full section text is captured (the first headless render printed only the visible viewport).","sourceUrl":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title26-section7454\u0026num=0\u0026edition=prelim","snapshot":"","fileExists":true,"fileBytes":157580,"grade":"primary","character":"statute","description":"","collection":"LEG-A","url":"/library/LAW-038","exhibitUrl":"/exhibit/LAW-038","citation":"Office of the Law Revision Counsel, 26 U.S.C. 7454 (OLRC current) (Sept. 26, 2026) (Ex. LAW-038)","stateName":"","related":["LAW-006","LAW-007","LAW-039","LAW-040","LAW-041"]}