Judicial review of a decision of the board of tax appeals shall be de novo in accordance with the provisions of RCW
82.32.180 or
84.68.020 as applicable except when the decision has been rendered pursuant to a formal hearing elected under RCW
82.03.140 or
82.03.190, in which event judicial review may be obtained only pursuant to RCW
34.05.510 through
34.05.598: PROVIDED, HOWEVER, That nothing herein shall be construed to modify the rights of a taxpayer conferred by RCW
82.32.180 and
84.68.020 to sue for tax refunds: AND PROVIDED FURTHER, That no review from a decision made pursuant to RCW
82.03.130(1)(a) may be obtained by a taxpayer unless within the petition period provided by RCW
34.05.542 the taxpayer shall have first paid in full the contested tax, together with all penalties and interest thereon, if any. The director of revenue shall have the same right of review from a decision made pursuant to RCW
82.03.130(1)(a) as does a taxpayer; and the director of revenue and all parties to an appeal under RCW
82.03.130(1)(e) shall have the right of review from a decision made pursuant to RCW
82.03.130(1)(e).