Texas Comptroller Amends Rules for Burden of Proof

The Texas Comptroller of Public Accounts adopted an amendment to 34 TAC 1.1.A.1.26 concerning burden and standard of proof in tax disputes. The amendment changes the requirement for taxpayers to produce records and supporting documentation from “contemporaneous” to “sufficient” when substantiating claims related to tax, penalties, or interest amounts in administrative or judicial proceedings. The regulation took effect May 11. [Tex. Comptroller of Pub. Accts., Reg. Section 34 TAC 1.26, 05/08/26 Tex. Reg.]