Burden of proof In civil court cases burden of proof on factual matters shifts to Irs if taxpayer does following Introduces credible evidence Complies w/ recordkeeping substantiation requirements of Irc Cooperates w/ reasonable requests Qualifies as a natural person or legal person w/ net worth < $7 million 88 Burden of Proof In civil court cases burden of proof on factual matters shifts to IRS if taxpayer does following: – Introduces “credible evidence” –Complies w/ recordkeeping & substantiation requirements of IRC –Cooperates w/ reasonable requests –Qualifies as a natural person or legal person w/ net worth  $7 million