In the practice of the tax law, the Parents transfer the money to the account opened on behalf of children, that will lead to gift tax levy by the Tax Collection Authority. The parents appeal to the Administrative Court by reason of without favor intention but the Court dismissed the vast majority notwithstanding. At this point, the reasons brought up from the judgement commented in the text that are very representative. What the key factors of success or failure of appeal refer to the following three important issues of Evidence Act in tax law is the focus of this article that will attempt to discuss: 1. Who should bear the burden of proof of favor intention of the grant between the plaintiff and their children; 2. How to judge the standard of proof in tax law; 3. Whether the taxpayer is with intent to gift, that is quite difficult to prove. Can it be overcome by the typification in tax law? What is the significance and application limitation of the typification in tax law?