The State Board of Equalization has the burden of proof of supporting its action which is the subject of the complaint. 68 O.S.Supp.1995 § 2881, (as amended by H.B. 1338, eff. July 1, 1997). The Oklahoma Tax Commission has the burden of proof of supporting its action which is the subject of the appeal. 68 O.S.1991 § 2883. Accordingly, the State Board of Equalization or the Oklahoma Tax Commission must first produce the evidence supporting its action. The complaining party must then produce the evidence in support of the complaint or protest. The parties may then produce rebutting evidence unless the panel, in furtherance of justice, permits the parties to offer further evidence in their original cases.
Okla. Stat. tit. 68, § 9