The Statement of Facts was lacking in that it did not explain why and how the Respondent’s decision is wrong.

The Tribunal has already noted that the Appellant’s Statement of Facts is a two-paragraph statement. Whereas the Memorandum of Appeal is comprehensive, the Statement of Facts was lacking in that it did not explain why and how the Respondent’s decision is wrong. The Tribunal finds that the Appellant’s Statement of Facts falls short of the requirements under Rule 5 of the Tax Appeals Tribunal (Procedure) Rules, 2015.