§13–516.

    (a)    To appeal to the Tax Court, a person or governmental unit shall file with the Tax Court a written petition that states succinctly:

        (1)    the nature of the case;

        (2)    the facts on which the appeal is based; and

        (3)    each question presented for review by the Tax Court.

    (b)    An opposing party shall respond in accordance with the rules of procedure of the Tax Court.