There is a minimum of three (3) commissioners appointed by the Governor General and their function is to preside over cases/decisions that have passed through the administrative review process but have been unsatisfactory to the taxpayer.
41. (1) The Governor General shall appoint Commissioners whose main function shall be to hear appeals against tax assessments but shall, in addition, perform any other functions that may be assigned to them by the Governor General from time to time.
(3) Three commissioners shall form a quorum at any meeting.
42. (2) An appeal to the Commissioners may not be made unless a request for administrative review has first been made, and a decision has been received from the Comptroller.