Key legal question
Whether the federal administrative court appeal met the formal pleading requirements.
Extracted holding
The filing was at least doubtful on form, but the court left the question open because the appeal was clearly unfounded.
Extracted reasoning
A complaint must contain specific requests and a reasoned challenge showing which parts of the decision are attacked and why. The taxpayer's submissions referred only generally to constitutional ability-to-pay principles and did not engage with the lower court's reasoning.