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Sec. 7427 Tax return preparers

  • Internal Revenue Code of 1986
  • SUBTITLE F -- PROCEDURE AND ADMINISTRATION
  • Chapter 76 -- Judicial Proceedings
  • Subchapter B -- Proceedings by Taxpayers and Third Parties

In any proceeding involving the issue of whether or not a tax return preparer has willfully attempted in any manner to understate the liability for tax (within the meaning of section 6694(b)), the burden of proof in respect of such issue shall be upon the Secretary.

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