705. Burden of proof; evidence.

Upon an appeal to the tribunal against an assessment, the onus is upon the taxpayer, by evidence given on oath or affirmation or by unsworn evidence1, to demonstrate that the assessment ought to be reduced or set aside2. If the appellant fails to lead evidence before the tribunal, he cannot have the assessment reduced or displaced3. Where the assessment would otherwise be out of time, the onus is on the Crown to raise a prima facie case of fraudulent or negligent conduct, but otherwise it remains on the taxpayer