Questione giuridica chiave
Whether the Federal Supreme Court could review the appellant's challenge to the factual findings and the rejection of his hardship arguments.
Decisione estratta
The appellant did not meet the qualified substantiation requirements; factual criticism was largely appellatory and the court would not review the challenged assessment further.
Motivazione estratta
The Federal Supreme Court is bound by the facts found below unless they are manifestly incorrect or unconstitutional; the appellant failed to show arbitrariness or a hearing violation in a sufficiently reasoned manner.