O) Burden of Proof

  1. In general, is the burden of proof on the taxpayer?

  2. Is the burden of proof where it involves the imposition of a penalty on the taxpayer?

  3. Is the State required to prove the facts for the justification of a penalty?

  4. Is the burden of proof to demonstrate the policy intent of legislation on the State?

  5. Is there a statute of limitations on when the tax authority can reassess or audit a taxpayer?

  6. Is the statute of limitations on audit and reassessment clearly stated in legislation?

  7. If the tax authority wishes to assess a taxpayer beyond the statute of limitations, is the burden on them to show that such action should be allowed?