It shall be presumed that any tax, interest, penalty or nontax debt assessed by the comptroller is due and owing until the contrary is established. The person assessed has the burden of proving with documentary evidence, books and records that any tax, interest, penalty or nontax debt assessed by the comptroller is not due and owing.
(Added Coun. J. 11-14-91, p. 7458; Amend Coun. J. 11-16-11, p. 13798, Art. I, § 3)