John F. Romann - Page 36

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               existing Tax Court rules the taxpayer has the burden of                
               proof as to matters in the notice of deficiency.  As to                
               matters raised by the Service at the time of the Tax Court             
               hearing, the Service has the burden.  It is expected that              
               rules similar to these will be adopted by the Tax Court.               
               The legislative language thus described in the Conference              
          Committee Joint Explanatory Statement was enacted as section 1041           
          of the Employee Retirement Income Security Act of 1974, Pub. L.             
          93-406, 88 Stat. 829, 949.                                                  

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