A quarterly magazine from the National Association of Enrolled Agents
Spring 2026 vol.44 no.1
When the Burden Shifts: Understanding Internal Revenue Code §7491(a)
Feature Article

When the Burden Shifts: Understanding Internal Revenue Code §7491(a)

The burden of proof in tax disputes generally is with the taxpayer, as established by Welch v. Helvering, 290 U.S. 111 (1933),i unless the taxpayer satisfies the conditions for burden shifting ... DeShawn King, EA

Fall 2025, Feature Article, IRS Restructuring and Reform Act of 1998, Cohan rule, §274(d), IRC §7491(a), Welch v. Helvering, §6001, §7491(c), burden of proof, Higbee v. Commissioner, Estate of Bongard, §2036