Any taxpayer, except one who has failed to comply with BMC 6.05.060, who has paid any tax as required and who feels aggrieved by the amount of the tax, and after first exhausting the right of administrative appeal set forth in this chapter, may seek judicial review in the Whatcom County superior court within 21 days of the entry of the city’s final administrative decision. The taxpayer shall set forth the amount of the tax imposed upon the taxpayer that the taxpayer concedes to be the correct amount of tax and the reason why the tax imposed should be reduced or abated. The appealing party shall serve a copy of the application for writ upon the opposing party within the time herein specified and shall file the original thereof, with proof of service with the clerk of the superior court of Washington for Whatcom County. The trial in the superior court on appeal shall be based upon the administrative record. The burden shall rest upon the taxpayer to prove that the tax as paid by the taxpayer is incorrect, either in the whole or in part, and to establish the correct amount of the tax. [Ord. 2002-12-106].