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Burden Of Proof And Choice Of Forum In Tax Litigation, George L. Whitfield, Charles E. Mccallum

Vanderbilt Law Review

Since the burden of proof may be a decisive factor in tax litigation, it is important that the taxpayer be aware of the different rules in the various forums to which he may take a tax controversy, and it is essential that those rules operate fairly and consistently to enable the taxpayer to choose his forum intelligently. It is the purpose of this article to examine the burden of proof in tax litigation as it affects the choice of forum problem.