Ayeni v. State

Although I join in the majority’s opinion and judgment — I wrote them, after all — I write separately to offer some additional observations about Ayeni’s second issue. While it was ultimately unnecessary for us to reach that issue here, it nonetheless warrants emphasis that Ayeni has identified an aberration in this Court’s past jurisprudence addressing the effect of Comptroller certificates of deficiency and how a taxpayer can oppose a summary-judgment motion predicated on one.

The notion that a taxpayer must present conclusive contrary evidence to rebut a Comptroller’s certificate of…