N.D. Cent. Code § 57-37.1-19
If the tax commissioner has disapproved a return, or an assessment or determination has been made by the tax commissioner pursuant to the provisions of this chapter and said assessment results in a liability that is in addition to that which has been reported, or is as a result of action taken by the tax commissioner pursuant to the provisions of section 57-37.1-17, the personal representative or any beneficiary has a right to a hearing before the tax commissioner. Written demand for a hearing must be made of the tax commissioner within thirty days from the disapproval of a return, or notice of assessment, or determination on such disapproval of return, or assessment, or determination and such person making demand for a hearing has a right to appeal to the district court from the decision of the tax commissioner on such hearing and all of the provisions of chapter 28-32 relating to proceedings before an administrative agency, including the right to appeal to the courts from the decision of the tax commissioner in such a proceeding, are applicable to and govern the notice of hearing, the hearing, and the right of appeal from the decision of the tax commissioner thereon.
N.D.C.C. § 57-37.1-19