Rule 6 The Petition: Contents

(a) THE PETITION.

(1) A civil proceeding is initiated by filing a petition with the Tax Division.

(2) A petition not substantially in accordance with section (b) may be accepted by the Court, provided the filing fee is paid and such petition contains at least sufficient information to show the jurisdiction of the Court and the alleged errors of which the petitioner complains. Upon notification by the Court to do so, the petitioner must file within such time as the Court must direct an amended petition conforming substantially to section (b).

(b) CONTENTS.

(1) In General. The petition must be filed on the applicable petition form maintained by the Tax Division or on a form that is substantially similar in content and form to that form and must include:

(A) The petitioner’s name and the address of the petitioner’s principal office or residence.

(B) The amount of tax in controversy, the nature of the tax, and the year(s) or the period(s) covered thereby.

(C) In each case, the petitioner must allege the facts relied upon to demonstrate that the jurisdictional requirements for the filing of petitions in the Tax Division have been met: In the case of a petitioner seeking review of an assessment of real property alleged to be exempt from taxation, the date of mailing of the denial of exemption; in all other cases, the date of payment of the amount owed (tax plus penalties and interest, if applicable), the date of the filing of a claim for refund, or the date of the mailing of the notice of disallowance of such claim, the date of the notice of deficiency assessment, or the date of the filing of an appeal with the Real Property Tax Appeals Commission, and, in the case of a petition brought by the District of Columbia, the date or receipt of the written decision of the Real Property Tax Appeals Commission.

(D) In separately lettered subparagraphs, clear and concise assignments of each and every error which the petitioner alleges to have been committed by the assessing authority.

(E) In separately lettered subparagraphs, a clear and concise statement of facts upon which the petitioner relies as sustaining each assignment of error, except those assignments of error in respect of which the burden of proof is upon the respondent.

(F) A prayer setting forth the relief sought by the petitioner.

(G) The signature of petitioner or petitioner’s counsel.

(2) The following additional information must be appended to the petition:

(A) If the appeal is for redetermination of a deficiency, (i) a copy of the statement of taxes due or the notice of assessment, and notice of deficiency, if any, and (ii) if a statement of reasons has accompanied the notice of assessment or notice of deficiency, so much thereof as is material to the issues set out in the assignments of error; or

(B) If the appeal is from the denial of a claim for refund, a copy of the notice of the denial thereof.

(3) The petitioner may append to the petition such other statements or documents as are material.

(c) [Deleted].

(d) [Deleted].

(e) [Deleted].