In all administrative proceedings, unless otherwise provided by law, the burden of proof shall be upon the taxpayer to show in what respect the action or proposed action of the Tax Commission is incorrect. If the taxpayer fails to prove a prima facie case, the Administrative Law Judge may recommend the Commission deny the relief sought solely upon the grounds of failure to prove sufficient facts which would entitle the taxpayer to the requested relief.
Okla. Admin. Code § 710:1-5-47