Neb. Rev. Stat. § 77-27,182

If the Department of Revenue receives a written application for a hearing, it shall proceed with notice and hearing as for a contested case pursuant to the Administrative Procedure Act. The validity and amount of the liability shall be determined and any adjustments made. No issues shall be reconsidered at the hearing which have previously been litigated. An appeal of the final decision may be made, and the appeal shall be in accordance with the Administrative Procedure Act.