At the adjudication stage you really need to have your ducks in a row, and will really benefit from having Hippocrates on your side, but at the appeal stage I think you can safely go with what you've written, because it looks like you're still at the stage of appealing to the Council. Even if presented with a watertight case, the council are very likely to reject, because they play the numbers and know a lot of people pay up at that stage even if they are on to a winner. After that you'll get a 'Notice to Owner', which is the point at which you can refer the case to the adjudicator.