Admissibility of non-admission complaint based solely on general attacks against the substantive correctness of the lower tax court's decision

§ 116 Abs. 3 Satz 3 FGO, § 115 Abs. 2 Nrn. 1, 2, 3 FGO, § 116 Abs. 5 Satz 2 2. Halbsatz FGO, § 107 FGO; Admissibility of non-admission complaint based solely on general attacks against the substantive correctness of the lower tax court's decision: The dispute concerned a challenge to the materially correct application of tax law, where the taxpayer argued against the merits of the financial court's decision without identifying specific procedural errors. Relying on Sections 116(3) sentence 3 and 115(2) numbers 1, 2, and 3 of the Fiscal Courts Act (FGO), the court held that general attacks on the substantive correctness of a lower instance decision are insufficient to justify a revision; the complaint must substantiate a specific ground for admission as defined by the statute. Additionally, the court noted the absence of a coherent application for a correction of the judgment pursuant to Section 107 FGO.