Your client Thabang is in dispute with the SARS. Thabang alleges that she submitted incorrect information when she submitted for her tax returns and therefore, SARS found her liable for taxes that she should not have been liable for. She received a letter from SARS with the following concerns:

Thabang informs you that she did submit the Request for Correction but SARS proceeded to inform her that the above mentioned form was only relevant for individual taxpayers who have submitted an ITI2S or ITI2C, which Thabang had not done. In her notice of appeal against this decision by SARS, Thabang requested Alternative Dispute Resolution with SARS.

FULLY advise Thabang on whether she is guaranteed alternative dispute resolution to resolve her matter with SARS. Also give her a critical discussion with regards to the circumstances under which she would not be guaranteed alternative dispute resolution. [15 MARKS]