to hold a hearing prior to its initial determinations or to bear the burden of proof in any hearing. See Mitchell v. W.T. Grant Co., 416 U.S. 600, 612, 94 S.Ct. 1895, 40 L.Ed.2d 406 (1974) (“[W]e have repeatedly held that no hearing at the preliminary stage is required by due process so long as the requisite hearing is held before the final administrative order becomes effective.” (internal quotation marks omitted)); Fairchild Semiconductor Corp. v. EPA, 984 F.2d 283, 289 (9th Cir.1993) (“It is sufficient [under the Due Process Clause], where only property rights are concerned, that there is at some stage an opportunity for a hearing and a judicial determination.” (alteration in original and internal quotation marks omitted)); Wilcox v. Comm’r, 848 F.2d 1007, 1008 (9th Cir.1988) (<HOLDING>). Plaintiffs substantive due process claim also
holding that taxpayer could not have presented substantive due process claim to the board of assessment review because of the limited jurisdiction of that board holding that the defendant bears the burden of proof and that such a disposition does not violate the due process clause holding that the burden of proof is on the claimant holding that placing the burden of proof on a taxpayer to demonstrate a tax deficiency assessment was incorrect did not violate due process holding that doctrine does not violate due process