The opening will, of course, vary according to whether the
taxpayer is representing himself or is represented by Counsel or
other professional adviser. The opening statement usually begins
with a systematic recital of the principal facts of the case. It
should also include sufficient detail from the documents to enable
the Commissioners to obtain a clear general idea of the points at
issue and of the circumstances of the case, so far as is favourable
to the appellant. It should also include a recital of the
application of statute relevant to the questions to be decided.
Any bundle of agreed documents are handed to the
Commissioners at this stage if the Commissioners have not already
been given them. Any other documents on which the appellant wishes
to rely but which do not form part of the agreed bundle are also
handed to the Commissioners. You should receive copies of these
latter documents if you have not already seen them.
There may follow a detailed statement of the appellant's
contentions after which the arguments may be elaborated, quoting as
necessary from decided Cases.
