Tax Court of Canada Rules (General Procedure)

60 A special case shall,

• (a) set out concisely the material facts, as agreed to by the parties, that are necessary to enable the Court to determine the question stated,

• (b) refer to and include a copy of any documents that are necessary to determine the question, and

• (c) set out the relief sought, as agreed on by the parties, on the determination of the question of law.