Section 524 - Civil proceeding involving State Board of Equalization(a) Notwithstanding any other provision of law, in a civil proceeding to which the State Board of Equalization is a party, that board shall have the burden of proof by clear and convincing evidence in sustaining its assertion of a penalty for intent to evade or fraud against a taxpayer, with respect to any factual issue relevant to ascertaining the liability of a taxpayer.(b) Nothing in this section shall be construed to override any requirement for a taxpayer to substantiate any item on a return or claim filed with the State Board of Equalization.(c) Nothing in this section shall subject a taxpayer to unreasonable search or access to records in violation of the United States Constitution, the California Constitution, or any other law.(d) For purposes of this section, "taxpayer" includes a person on whom fees administered by the State Board of Equalization are imposed. Added by Stats 2010 ch 168 (AB 2195),s 1, eff. 1/1/2011.