§6902 Provisions of Special Application to Transferees

Summary

The IRS must prove in Tax Court that a person who got a taxpayer’s property is legally responsible as a transferee. The IRS does not have to prove that the original taxpayer actually owed the tax. A transferee who is asking the Tax Court to decide their liability can ask, under court rules, for a preliminary look at the taxpayer’s or earlier transferees’ books and papers. The Tax Court can order a judge-signed subpoena for records in the United States if those records are needed to decide liability and if forcing production would not cause undue hardship. The court will set the time and place for the review.