Burden of proof
(a) In proceedings before the district court the burden of proof shall be upon the Director to show that a petitioner is liable as a transferee of property of a taxpayer, but not to show that the taxpayer was liable for the tax.
Evidence
(b) Upon application to the district court, a transferee of property of a taxpayer shall be entitled, under rules prescribed by the district court, to a preliminary examination of books, papers, documents, correspondence, and other evidence of the taxpayer or a preceding transferee of the taxpayer's property, if the transferee making the application is a petitioner before the district court for the redetermination of his liability in respect of the tax (including interest, additional amounts, and additions to the tax provided by law) imposed upon the taxpayer. Upon such application, the district court may require by subpoena, ordered by the district court and signed by a judge, the production of all such books, papers, documents, correspondence, and other evidence within the Virgin Islands the production of which, in the opinion of the district court, is necessary to enable the transferee to ascertain the liability of the taxpayer or preceding transferee and will not result in undue hardship to the taxpayer or preceding transferee. Such examination shall be had at such time and place as may be designated in the subpoena.