In a recent Wyoming appeals case it was upheld that the Department of Audit’s use of estimates to determine tax owed was legal in some instances. Wyoming law states that if a taxpayer’s records are insufficient, an auditor can use reasonable estimates to determine a taxpayer’s liability. Wyoming law places the ultimate burden of proof on the taxpayer as to the completeness and accuracy of records and amounts due to the government. If a taxpayer provides sufficient evidence that their tax liability is different than what the state determined under audit, the burden becomes the state’s to prove otherwise. (Appeal of Ronald E. Waugh d/b/a Capt’n Ron’s Rodeo Bar, Docket No. 2003-24, May 11, 2004.)