63-3027D — PRESUMPTIONS AND BURDENS OF PROOF

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                                  TITLE  63
                             REVENUE AND TAXATION
                                  CHAPTER 30
                                  INCOME TAX
    63-3027D.  PRESUMPTIONS AND BURDENS OF PROOF. (a) A qualified taxpayer and
its affiliates shall be presumed to be a part of a unitary business and all
income of that business shall be presumed to be apportionable business income
if a valid water's-edge election has been made, except as provided in
subsections (c) and (d) of section 63-3027C, Idaho Code.
    (b)  A taxpayer shall have the burden of proof regarding the issue of
whether or not a corporation is a member of a water's-edge combined group.