A motion to restrain assessment or collection or to order refund of any amount collected may be filed with the Court only where a timely petition has been filed with the Court. See Code secs.
6015
(e)(1)(B)(ii),
6213
(a),
6225
(b), and
6246
(b). For the rules applicable to captions, signing, and other matters of form and style of motions, see Rule
50
(a).