(a) Any hearing granted by the Commissioner under section 10109 of this title shall be subject to and governed by 3 V.S.A. chapter 25.
(b) Any aggrieved taxpayer may, within 30 days, appeal a determination by the Commissioner concerning a notice of deficiency, an assessment of penalty or interest, or a claim to refund to the Washington Superior Court or the Superior Court of the county in which the taxpayer resides or has a place of business by filing a notice of appeal and either paying or giving security, approved by the Commissioner, for the payment of any tax liability that may be determined to be due and costs of appeal.