SEC. 506. BURDEN OF PERSUASION AND BURDEN OF PRODUCTION.
`In all disputes concerning taxes imposed by this subtitle, the person engaged in a dispute with the sales tax administering authority or the Secretary, as the case may be, shall have the burden of production of documents and records but the sales tax administering authority or the Secretary shall have the burden of persuasion.
You really have no arguement unless you can dispute what this paragraph clearly says, but you can't.
Since I have a limited amount of time to spend posting to these threads, I took the time to read the posts following yours and can add nothing to what has already been posted by others.