California, United States of America
The following excerpt is from Combs v. Haddock, 11 Cal.Rptr. 865, 190 Cal.App.2d 151 (Cal. App. 1961):
The burden of establishing the account is on the trustee, including the burden of showing that any expenditure made was a proper disbursement. Purdy v. Johnson, 174 Cal. 521, 163 P. 893; 49 Cal.Jur.2d p. 160.
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