Following the issuance of a final determination of the tax commissioner pursuant to section 40-226.3, the taxpayer or commissioner of the revenue or other assessing official may apply
to the appropriate circuit court for judicial review of the determination, or any
part thereof, pursuant to section 40-227. In any such proceeding for judicial review of a determination of the tax commissioner,
the burden shall be on the party challenging the determination of the tax commissioner,
or any part thereof, to show that the ruling of the tax commissioner is erroneous
with respect to the part challenged. Neither the tax commissioner nor the department
of taxation shall be made a party to an application to correct an assessment merely
because the tax commissioner has ruled on it.
(Ord. No. 6254-06, § 1)
