Utah Code Title 59. Revenue and Taxation § 59-1-1005. Suits against commission and its employees

(1) A taxpayer may bring a civil suit against the commission for recovery of actual damages and costs incurred by the taxpayer if:

(2) An award of actual damages and court costs in a suit under this section may not exceed $100,000.

(3) If the court finds that the civil action brought by the taxpayer is frivolous, the court may impose a penalty of up to $10,000 against the taxpayer.