(1)

Any order of assessment made under this Act shall be conclusive evidence in any prosecution or other proceeding.

(2)

The validity of the assessment of any tax, or of the levy of any fee or other amount, made under this Act, or the liability of any person to pay any tax, fee or other amount so assessed or levied, shall not be questioned in any criminal court in any prosecution or other proceeding, whether under this Act or otherwise.