Mr. Gerry Smyth:

That is a difficult question to answer because, as I stated in my opening remarks, there are very different kinds of disputes. There can be a dispute which is really only about the facts. Take, for example, a tax payer who has not kept proper records. There is no real dispute about the law. The dispute is about the amount of profits for the year. In a situation such as this, there is a dispute between the Revenue officer and the individual. There are no records so it is necessary to make some kind of an estimate. A lot of haggling goes on as people try to decide what is acceptable.