A Notice of Appeal to the Tribunal is only valid if the taxpayer has paid tax not in dispute or entered into an arrangement with the Commissioner to pay the tax not in dispute

“Considering the foregoing, the Tribunal is left with no alternative but to take notice of the fact that there being no written communication from the Respondent of its non-acceptance of the Appellant's proposal, it makes a finding that the Appellant would not make arrangements of payment of the taxes in dispute without a response from the Respondent. Having failed to respond the Respondent cannot turn round and state that the payment was not acceptable.”