Leffler contends that the Board's findings of fact are not supported by substantial evidence and the Board erroneously interpreted the law when it found that he was the sole proprietor of Choices and that Bob Hosford and Duncan were not partners. Judicial review of a final notice of assessment by the Board is governed by the Administrative Procedure Act, RCW 34.05.510 through .598. RCW 51.48.131; Maplewood Estate, Inc. v. Dept. of Labor and Industries, 104 Wn. App. 299, 304, 17 P.3d 621 (2000). The employer has the burden to prove that the taxes and penalties were incorrect. RCW 34.05.570(1)(a).
Substantial evidence is evidence sufficient to persuade a rational, fair-minded person of the finding's truth. Maplewood Estate, Inc. v. Dep't of Labor & Indus., 104 Wash.App. 299, 304, 17 P.3d 621 (2000). This court need only consider whether the evidence most favorable to the prevailing party supports the challenged findings, even if the evidence is in conflict.
Substantial evidence is evidence sufficient to persuade a rational, fair-minded person of the finding's truth. Maplewood Estate, Inc. v. Dep't of Labor & Indus., 104 Wash.App. 299, 304, 17 P.3d 621 (2000).
Substantial evidence is evidence sufficient to persuade a rational, fair-minded person of the finding's truth. Maplewood Estate, Inc. v. Dep't of Labor & Indus., 104 Wash.App. 299, 304, 17 P.3d 621 (2000). ΒΆ 20 The reviewing court is to view the evidence and the reasonable inferences therefrom in the light most favorable to the party who prevailed at the administrative proceeding below.