ITO Section 136 | Burden of proof.

ITO Section 136

Burden of proof:

In any appeal  [by a taxpayer] under this Part, the burden shall be on the taxpayer to prove, on the balance of probabilities —

• (a) in the case of an assessment order, the extent to which the order does not correctly reflect the taxpayer’s tax liability for the tax year; or
• (b) in the case of any other decision, that the decision is erroneous.