Decision on tax residency status did not require detailed reasons in the absence of supporting evidence

Judicial review - decisions of appeal commissioner of tax appeals commission - alleged failure to give reasons for decisions in tax appeal - tax assessments raised by criminal assets bureau in respect of applicants - statutory framework for taxation appeals - case made on appeal that applicants were not tax resident in the State and accordingly they did not have to file a tax return or pay tax - appeal hearing - evidence heard that returns had been filed for a number of years yet applicants' tax advisor claimed they were nonetheless not tax residents in State - no documentary evidence presented to support alleged 'non-residency' status for tax purposes - whether wording of appeals commissioner's decision fatally undermined by a failure to set out reasons for decision - legal principles pertaining to need for decision makers to give reasons - rationale - extent of requirement to give reasons will depend on nature and extent of conflicting evidence before decision maker - Court unconcerned with whether appeals commissioner might have expressed his decision better - whether enough information provided to enable applicants to understand decision and consider an appeal/judicial review - straightforward factual/credibility dispute - decision on bare assertions made to decision maker - no evidence presented by applicants to decision maker - application refused.