1. Before a person may seek judicial review pursuant to NRS 233B.130 from a final decision of the Nevada Tax Commission pursuant to this chapter, the person must:
(a) Pay the amount of any outstanding liability as set forth in the final decision; or
(b) Enter into a written agreement with the Department establishing a later date by which he or she must pay the amount of the outstanding tax liability.
2. If a court determines that the amount of any outstanding tax liability set forth in the final decision should be reduced or that the person does not owe any taxes, the Department shall credit or refund any amount paid by the person that exceeds the amount owed, with interest determined in accordance with NRS 360.2935.