(A) Within five days after the day on which a jeopardy assessment is made, the department shall provide the taxpayer with a written statement of the information the department relied on in making the assessment.
(B) Within thirty days after the day on which the taxpayer is furnished the written statement described in subsection (A), or within thirty days after the last day of the period within which the statement is required to be furnished, the taxpayer may request a contested case hearing before the Administrative Law Judge Division. Requests for a hearing before the Administrative Law Judge Division must be made in accordance with its rules. The only issue for determination under this subsection is whether the jeopardy assessment is reasonable and appropriate.
(C) Within ten days after an action is commenced under subsection (B), the department shall file its response with the Administrative Law Judge Division. Within twenty days after the department's response or as soon thereafter as practicable, an Administrative Law Judge shall determine whether or not the making of the jeopardy assessment is reasonable under the circumstances, and whether the amount so assessed or demanded as a result of the action taken under Section 12-60-910 is appropriate under the circumstances. The running of the ten-day and twenty-day periods begins on the day on which service is made on the department.
(D) If the Administrative Law Judge determines that the making of the jeopardy assessment is unreasonable or that the amount assessed or demanded is inappropriate, he may order the department to abate the assessment, to redetermine, in whole or in part, the amount assessed or demanded, or to take other action as the judge finds appropriate.
(E) The decision made by the Administrative Law Judge under this section is final and conclusive and may not be reviewed by any court.
(F)
(1) In an action under subsection (B) involving the issue of whether the making of an assessment under Section 12-60-910 is reasonable under the circumstances, the burden of proof in respect to the issue is on the department.
(2) In an action under subsection (B) involving the issue of whether an amount assessed or demanded as a result of action taken under Section 12-60-910 is appropriate under the circumstances, the department shall provide a written statement containing any information on which its determination of the amount assessed was based, but the burden of proof in respect to the issue is on the taxpayer.