(1)
General rule
If, in any court proceeding, a taxpayer introduces credible evidence with respect to any factual issue relevant to ascertaining the liability of the taxpayer for any tax imposed by subtitle A or B, the Secretary shall have the burden of proof with respect to such issue.
(2)
Limitations
Paragraph (1) shall apply with respect to an issue only if—
(A)
the taxpayer has complied with the requirements under this title to substantiate any item;
(B)
the taxpayer has maintained all records required under this title and has cooperated with reasonable requests by the Secretary for witnesses, information, documents, meetings, and interviews; and
(C)
in the case of a partnership, corporation, or trust, the taxpayer is described in section
7430
(c)(4)(A)(ii).
Subparagraph (C) shall not apply to any qualified revocable trust (as defined in section
645
(b)(1)) with respect to liability for tax for any taxable year ending after the date of the decedent’s death and before the applicable date (as defined in section
645
(b)(2)).