Dissenting Opinion by
BAY MITCHELL, Presiding Judge:¶ 1 The majority’s opinion hinges on imposing a burden of “strict proof’ on Visteon to prove compliance with the notice provision in 68 O.S.2001 § 2884(B) to establish the district court’s jurisdiction to hear its appeal. Their sole authority is Macsuga v. Moreno, 2003 OK 24, ¶ 5, 66 P.3d 409, 411, a worker’s compensation case that holds the claimant “must be held to strict proof that he was an employee of [respondant/employer] in order to be covered by the provisions of the [Workers’ Compensation] Act.” I disagree that strict proof is required and would instead only require that Visteon prove by “competent evidence” that they gave notice of their protest to the County Treasurer.
¶2 The statute we must interpret is 68 O.S.2001 § 2884(B), which provides:
When such taxes are paid, or by December 31, whichever is earlier, the persons protesting the taxes shall give notice to the county treasurer that an appeal involving such taxes has been taken and is pending, and shall set forth the total amount of tax that has been paid under protest ... The notice shall be on a form prescribed by the *697Tax Commission ... The taxpayer shall attach to such notice a copy of the petition filed in the court or other appellate body in which the appeal was taken ...
Id. (emphasis added). Nothing in § 2884 requires that taxpayers be held to strict proof of compliance with the notice provision or suffer the consequence of dismissal of their appeals.
¶ 3 I recognize Oklahoma cases have held that the notice requirement in § 2884(B) is jurisdictional. See Means v. Blevins, 1995 OK 76, 898 P.2d 1286; Dolese Bros. Co. v. Board of Comm’rs of Comanche County, 1931 OK 480, 2 P.2d 955. However, in those cases, it was undisputed that the taxpayers did not give proper notice of protest. The cases did not discuss the applicable burden of proof when the jurisdictional facts are disputed. This is an issue of first impression in Oklahoma that must be determined by interpreting this statute in accord with the Oklahoma Tax Code as a whole. For several reasons, I believe that competent evidence is the correct burden of proof to satisfy the notice requirement of § 2884(B). Visteon clearly met that burden with the evidence they presented.
¶ 4 First, there is no justification for applying the burden of strict proof from the Workers’ Compensation Act to this notice provision. The majority opinion cites Macsuga, 2003 OK 24, 66 P.3d 409, for the proposition that the party seeking to establish jurisdiction is alivays held to strict proof. This is not an accurate statement of Oklahoma law. For example, a plaintiff only has the burden of proving the jurisdictional requirement of in personam jurisdiction by a “preponderance of the evidence.” Jim Marrs Drilling Co., Inc. v. Woolard, 1981 OK CIV APP 23, ¶ 18, 629 P.2d 810, 813; see also Union Bank v. Ferris, 1978 OK 149, ¶ 5, 587 P.2d 454, 455 (emphasizing personal jurisdiction over nonresident defendants “must affirmatively appear from the record”). This is a standard somewhat less than preponderance of the evidence and probably akin to competent evidence. Similarly, in order to satisfy the jurisdictional requirement of timely filing the petition in error to commence an appeal, the appellant only has to prove they timely deposited the document in the United States mail, postage prepaid. 12 O.S. Supp.2002 § 990A(B). Significantly, the only proof required is the postmark affixed to the properly-addressed mail. Id.; Whitehead v. Tulsa Public Schools, 1998 OK 71, ¶ 5, 968 P.2d 1211, 1214 n. 10 (noting a postmark affixed to certified, priority or first class mail is proof of timely mailing). Even in federal courts, where the courts must presume there is no jurisdiction because they are courts of limited jurisdiction, the burden of proof for jurisdiction is no higher than preponderance of the evidence. See, e.g., Thomson v. Gaskill, 315 U.S. 442, 446, 62 S.Ct. 673, 675, 86 L.Ed. 951 (1942) (stating party asserting diversity jurisdiction must provide “competent proof’); McBride v. CITGO Petroleum Corp., 281 F.3d 1099, 1106 (10th Cir.2002) (stating plaintiff has the burden of proving subject matter jurisdiction requirement of exhaustion of administrative remedies by competent evidence); U.S. ex rel Stone v. Rockwell Intern. Corp., 282 F.3d 787, 797-98 (10th Cir.2002) (applying preponderance of evidence burden to review subject matter jurisdiction requirements under federal False Claims Act); U.S. ex rel. King v. Hillcrest Health Center, Inc., 264 F.3d 1271, 1278 (10th Cir.2001) (emphasizing federal courts are courts of limited jurisdiction and party alleging jurisdiction has burden of “alleging the facts critical to jurisdiction and coming forth with competent proof.”). There are varying standards of proof for jurisdictional requirements. Choosing a burden of “strict proof’ without any discussion or justification is unwarranted.
¶ 5 There is no similarity between the requirement of notice in § 2884(B) and the requirement that a claimant show he is an employee under the Workers’ Compensation Act that justifies imposing the same burden of strict proof. Strict proof is required to establish workers’ compensation jurisdiction because that system is set up to only provide benefits to employees. Establishing an employer/employee relationship is a condition precedent for establishing jurisdiction. If the workers’ compensation claimant cannot prove the existence of the necessary employment relationship, the Act is inapplicable and *698the claimant is not entitled to workers’ compensation benefits.
¶ 6 Here, by contrast, the majority’s application of the standard of strict proof operates to dismiss a pending appeal that is proper in all other respects, even though the taxpayer had taken all reasonable steps to comply with the notice requirement. Compliance with § 2884 was not a condition precedent to filing this appeal. Instead, the appeal had already been initiated by filing a Petition in the district court after the taxpayer had exhausted their administrative remedies by unsuccessfully appealing the County Assessor’s valuation to the Board of Equalization. There is no statutory or policy justification for applying the heavy burden of strict proof to the notice requirement in § 2884(B) when the appeal is pending and proper in all other respects.
¶ 7 Second, the Legislature provided in § 221.1 of the Uniform Tax Procedure Code1 that mailing by registered mail is prima facie evidence that the document was actually delivered to the agency to which it was addressed. 68 O.S.2001 § 221.1. The relevant portions of this provision provide:
A. For any return, claim, statement, or other document required to be filed or any payment required to be made within a prescribed period ... under authority of any provision of a tax law of this state, the date of the postmark stamped on the cover ... shall be deemed to be the date of delivery or the date of payment, as the case may be.
B. The provisions of this section shall apply only if: ...
2. The ... document or payment was ... deposited in the mail in the United States in an envelope or other appropriate wrapper, postage prepaid, properly addressed to the ... office with which the ... document is required to be filed
* ⅜ ⅜ ⅜
D. For purposes of this section, if any ... document or payment, is sent by United States registered mail, the registration shall be prima facie evidence that the ... document was delivered to the ... office to which addressed, and the date of registration shall be deemed the postmark date. The Tax Commission is authorized to provide by rules or regulations the extent to which the foregoing provisions of this subsection with respect to prima facie evidence of delivery and the postmark date shall apply to certified mail ...
68 O.S.2001 § 221.1.
¶ 8 The purpose of the Uniform Tax Procedure Code is to provide uniform procedures and remedies for all state taxes, and its provisions “shall control and shall be exclusive” unless expressly excluded by a specific state tax law. 68 O.S.2001 § 201. Nothing in the Ad Valorem Tax Code (68 O.S.2001 §§ 2801-3152) or § 2884 in particular, excludes the application of the presumptive mailing rule in § 221.1. In fact, requiring strict proof of notice is in direct conflict with the presumption of prima facie evidence of delivery.
¶ 9 Another strong argument for applying the presumptive mailing rule to the notice of protest required in § 2884 is that there is a presumptive mailing provision in 68 O.S.2001 § 2876, which sets out the procedure for notification by the County Assessor to the taxpayer of an increase in the assessed value of the taxpayer’s property. If the County Assessor increases the valuation of a taxpayer’s property, the assessor is only required to give written notice to the taxpayer. 68 O.S. 2001 § 2876(A). That notice is adequate if it is “mailed or delivered to the last known address” of the taxpayer. § 2876(C). “Duplicate copies of the notice showing the date of issuance and mailing or delivery, shall be kept in. the office of the county assessor ... [and] shall be prima facie evidence as to the fact of notice having been given as required by this section.” Id. (emphasis added); see also 68 O.S.2001 § 208 (provision of Uniform Tax Procedure Code that specifically states mailing to last-known address “shall be pre*699sumptive evidence of receipt” for any notice Tax Commission must give, and failure to actually receive notice does not invalidate Commission’s action or relieve taxpayer of interest or penalties). The taxpayer then has twenty days “from the date the notice was mailed ... in which to file a written complaint with the county assessor ...” § 2876(D). The assessor shall notify the taxpayer of the final action taken and it is only required that the “notice shall be mailed or delivered within one working day” of the action taken. § 2876(F). The taxpayer may then appeal to the County Board of Equalization by mailing or delivering a copy of the appeal form to the county assessor and another to the equalization board. Id. Written notice is required at each stage of this protest/appeal process, but nowhere in this statutory scheme is there a requirement that notice be proven by anything approaching “strict proof’ or that “receipt” of the notice must be proven. Interpreting § 2884 as requiring strict proof of notice is a serious and unwarranted inconsistency with § 2876. Thus, the proof of mailing presumptions should clearly apply to the notice requirement in § 2884, and proof of mailing by registered or certified mail is prima facie evidence of delivery on the date marked on the mail.
¶ 10 Regulations by the Oklahoma Tax Commission have further specified that the date of the United States postmark is the date of filing for “any claim, statement, or other document required by law or agency Rule to be filed ...”. Oklahoma Administrative Code 710:1-3-30. Further, the regulations provide that when a document is sent by certified mail, the date of the postmark on the receipt is the date of the delivery. Oklahoma Administrative Code 710:1-3-32. Importantly, these presumptive mailing rules apply even if the document is not actually received, as noted in regulation 710:65-3-2 titled “Timely Mailing Treated as Timely Filing and Paying,” which provides:
(a) Any report, claim, tax return, statement or other document required or authorized to be filed with or any payment made to the Commission, which document or payment is transmitted through the United States mail, will be deemed to have been filed with and received by the Commission on the date shown by the post office cancellation mark stamped upon the envelope or other appropriate wrapper containing it. If mailed but not received by the Commission, or if received but the cancellation mark is illegible, erroneous or omitted, or envelope unavailable, the document or payment will be deemed to have been filed on the date it was mailed if the sender establishes by competent evidence that the document or payment was deposited in the United States mail on or before the date due for filing ...
(b) If any ... document is sent by United States registered mail, certified mail or certificate of mailing, a record authenticated by the United States Post Office of such registration, certificate or certificates shall be considered competent evidence that the ... document was mailed, and the date of registration, certification or certificate shall be deemed to be the date of the postmark made by the United States Postal Service.
Okla. Admin. Code 710:65-3-2 (emphasis added).
¶ 11 Thus, under this regulation, only competent evidence is required to prove filing of any document with the Oklahoma Tax Commission. Further, a receipt for certified mail, standing alone, is competent evidence to satisfy this burden of proof. Although this regulation is listed under the section for sales tax, its plain language applies to any document required to be filed with the Commission. Also, it refers to Oklahoma Administrative Code regulations 710:1-3-30 and 710:1-3-31, the general regulations regarding filing by mailing that apply to any document or act required by the Oklahoma Tax Code. Section 2884 does not set out any different standard for providing notice to the County Treasurer than that established for all filings submitted to the Tax Commission, and there is no justification for establishing a different rule where the statute is silent as to the burden of proof.'
¶ 12 Oklahoma eases have applied the general “presumptive mailing rule” in several other areas where notice is required. This *700rule provides: “When a letter is placed in the mail system bearing a correct address and sufficient postage to reach its destination, a rebuttable presumption arises that the letter did in fact reach the addressee. In the absence of sufficient rebuttal evidence, the presumption prevails.” Booth v. McKnight, 2003 OK 49, ¶ 3, 70 P.3d 855, 858 n. 6 (applying presumptive mailing rule to notice of hearing required for final accounting in probate action) (emphasis in original); see also Shamblin v. Beasley, 1998 OK 88, ¶ 23, 967 P.2d 1200, 1212 n. 51 (applying presumption of mailing to pre-sale notice of tax sale); Liberty Plan Co. v. Francis Smith Lumber Co., 1961 OK 30, ¶ 14, 360 P.2d 500, 504 (applying presumption of receipt of properly addressed letter to notice of claim required to enforce mechanic’s lien); 12 O.S.2001, Ch. 15, App. 1, Okla. Sup.Ct. R. 1.4(c) (stating a petition in error that is mailed by the United States Postal Service is considered filed with the Oklahoma Supreme Court on the date of the postmark).
¶ 13 The only burden required should be “competent proof,” as stated in Oklahoma Administrative Code 65-3-2, and that burden was satisfied by Visteon sending the protest certified mail, return receipt requested.
¶ 14 Finally, the burden imposed by the majority conflicts with mandatory rules of statutory construction for taxation cases and for appellate cases. As a general rule, courts will liberally construe appellate statutes to further justice and to favor the right of appeal. AP-Prescott One Ten LP v. Clay, 2001 OK CIV APP 128, ¶ 11, 34 P.3d 1169, 1171; City of Tulsa v. Board of Trustees of Police Pension & Retirement System, 1963 OK 267, ¶ 8, 387 P.2d 255, 258 (stating statutes giving the right of appeal “should be liberally construed in furtherance of justice ... ”).
¶ 15 Further, tax laws must be strictly construed against the State, and any ambiguity must be resolved in favor of the taxpayer. See, e.g., Samson Hydrocarbons Co. v. Oklahoma Tax Comm’n, 1998 OK 82, ¶ 8, 976 P.2d 532, 536. The majority opinion recognizes this rule, but then ignores it by choosing the strictest burden of proof and imposing it on the taxpayer without justifying why this burden should apply in an ad valorem tax appeal. The effect of applying this burden of proof is to greatly favor the county, in contradiction of our rules of construction in tax cases. Oklahoma courts do not have any discretion to ignore these canons of construction and impose by judicial fiat a burden of strict proof that was not intended by the Legislature.
¶ 16 When applying these rules of construction and policies that protect the taxpayer’s appeal to the notice requirement in § 2884(B), it is clear the burden of proof for complying with the notice provision should only be the same competent evidence test required for proving filing of any document or payment with the Oklahoma Tax Commission. I recognize that the purpose of the notice provision is to allow the treasurer to apportion all payments that are not protested and not be forced to refund sums that have already been apportioned. 68 O.S.2001 § 2884(C). However, this purpose does not override the requirement that tax statutes be strictly construed in favor of the taxpayer. If the Legislature had wanted to impose a burden of strict proof to protect the County Treasurer’s office, they certainly could have done so, but they did not. Instead, they established the presumptive mailing rule in § 221.1, and did not exclude this rule from applying to § 2884. Where the taxpayer proves they gave notice of the protest by proper mailing, the risk that the notice was not actually received or not processed correctly by the treasurer’s office should not fall on the taxpayer by taking away his right to appeal.
¶ 17 When the burden of strict proof requirement is removed and the competent evidence test is applied, it is clear that Visteon produced more than competent evidence that they complied with the notice provision in § 2884. Visteon produced evidence that they mailed the protest packet with their tax payment check by certified mail, return receipt requested. Visteon attached an affidavit from their general counsel stating she prepared the protest form and gave the form and the petition to their tax consultant. Vis-teon also included an affidavit from the tax consultant stating she placed all the protest information in the envelope with the check *701and sent it by certified mail to the County Treasurer’s office. The signed receipt was returned evidencing delivery and receipt. Visteon also received a receipt showing their check had been processed. Since all the information was sent together, Visteon had no reason to suspect the County Treasurer’s office had not received or processed the protest information. Visteon produced its copy of the signed and dated notice of protest form and a copy of the petition they sent to the Treasurer’s office. Visteon also produced copies of several ermails showing they knew exactly what was required by § 2884 and setting out their procedure for complying with the requirements provided therein. This evidence is certainly competent proof that Visteon sent all of their protest information with their tax payment by certified mail to the County Treasurer’s office and that it was received.
¶ 18 On the other hand, the Treasurer’s office produced evidence that they did not actually receive Visteon’s protest packet. They produced affidavits from the person who normally opens this mail and the person who processes these protests, who stated they did not see a protest by Visteon. This evidence, however, is not sufficient to overcome the presumption of receipt because there were deficiencies and gaps in their evidence and in their procedure for processing these protests.
¶ 19 The majority opinion discusses some of the relevant evidentiary material, but there is additional critical evidence that it fails to mention. Keith Hamilton, the Chief Deputy Treasurer for Tulsa County, testified in his deposition that the majority of tax payments are processed by an outside company, Bank of Oklahoma (BOK). He estimated that out of 200,000 payments received per year, only 30,000 are actually processed by the Tulsa County Treasurer’s Office. For the rest of the payments, an employee from BOK opens the envelope and processes any standard payment. However, BOK employees forward any nonstandard payments to the Treasurer’s office for processing. Nonstandard payments include partial payments, delinquent payments and payments that include protests.
¶ 20 The majority also fails to point out that the mail room maintains a log of all certified mail received by Treasurer’s office. Interestingly, Visteon’s certified mail was not listed in the log even though it was undisputed Visteon’s check was actually received by the Treasurer’s office' and the certified mail receipt was signed and returned to Visteon. Brad Schell, an employee in Administrative Services for Tulsa County, testified that it.is standard procedure to log-in all certified mail that comes directly to the Tulsa County Treasurer. Since Visteon’s mail was not logged in, it is probable that Visteon’s mail was initially received and opened by the outside processor and then forwarded with other nonstandard payments to the Treasurer’s office. The only reason this payment would be nonstandard would be if it included protest information. The payment was not late and it was not a partial payment. Thus, the Treasurer’s office should have known when they received Visteon’s payment that it was nonstandard.
¶21 The Treasurer’s office failed to provide any evidence that Visteon’s payment was not initially handled by BOK and then forwarded to the Treasurer’s office. They did not include any affidavits from employees at BOK stating that they did not see a protest from Visteon. In light of the evidence presented and the reasonable inferences drawn therefrom it is quite possible the protest information was lost or misplaced when the envelope was opened by BOK or forwarded to the Treasurer’s office. The Treasurer’s department also admitted that they routinely throw away the envelopes and the check stubs, which could have resulted in Visteon’s protest information being accidentally discarded. Because of the evidentiary gaps and the potential problems in the processing of protests, the Treasurer’s proof that they did not receive the protest is less probative than Visteon’s direct proof of compliance.
¶ 22 The evidence demonstrates that Vis-teon took all reasonable steps to comply with the notice provision and be able to prove compliance if necessary. In the normal course of business, proof of mailing is usually accomplished by certified mail and by keep-*702tag a copy of the information that was mailed. This method is specifically authorized by 68 O.S.2001 § 221.1 and regulations of the OHahoma Tax Commission. Further, Visteon’s general counsel and tax consultant are located out-of-state in Michigan. It would not be reasonable to expect them to hand-deliver the protest information. It is also not reasonable to require them to demand proof of receipt of their protest notice. The statutes set out all the steps a taxpayer must take. It does not require hand-delivery and it does not require proof of receipt in order to satisfy the notice provision. Visteon received proof that their envelope had been received and also received proof that their payment had been processed. They were entitled to assume their notice of protest had also been received. The law does not require anything more of Visteon to preserve their right to appeal. Any other decision would jeopardize taxpayers’ rights to appeal when they have taken all reasonable steps to give the required notice to the Treasurer’s office. In addition, it would reward the County when the Treasurer’s office fails to properly process notices of protest.
¶23 For these reasons, I would reverse the trial court’s dismissal of Visteon’s appeal and remand to allow the appeal in district court to continue. The affidavits by Vis-teon’s employees that they specifically remember sending the protest information with their tax payment, coupled with the signed and dated copies of the protest documents and the certified receipt of their mailing constitute competent evidence that they gave notice of their protest to the County Treasurer’s office. Visteon satisfied their burden under § 2884. '“Strict proof’ is not, and should not be required.
. Article 2 of the Oklahoma Tax Code (68 O.S. §§ 201-264) is designated in § 201 as the "Uniform Tax Procedure Code.”