The taxpayer must exhaust the administrative remedies prescribed by law prior to appealing from an order of the Tax Commission, except in cases involving Constitutional issues as outlined in Title 68 O.S. § 226(c). (See, Cimarron Industries, Inc. v. Oklahoma Tax Commission, 1980 OK 190, 621 P.2d 539.)
Okla. Admin. Code § 710:1-5-43