In all administrative proceedings, unless otherwise provided by law, the burden of proof shall be upon the taxpayer/registrant to show in what respect the action or proposed action of the Commission is incorrect. If, upon hearing, the taxpayer/registrant fails to make a prima facie case, the Administrative Law Judge may recommend that the Commission deny the application solely upon the grounds of failure to prove sufficient facts which would entitle the taxpayer/registrant to the requested relief.
Okla. Admin. Code § 165:5-25-4