Mr. John O'Callaghan:

I will answer in some detail. In many cases, unless we have proper submissions beforehand, we would not know what was happening. The appeal would be heard and people would make arguments in front of us without having worked them out. For technical cases, we required and asked for full written submissions. The taxpayer is obliged under what used to be section 957 to provide in detail the grounds for an appeal before he or she is entitled to an appeal. We found that requiring those submissions put discipline on people. When we receive a taxpayer's submission, we look for replies from Revenue. Once we have received a taxpayer's submission, he or she will have a case heard within two months. When Revenue requests a listing for a hearing, we write immediately to the taxpayer and ask for his or her submissions within two months. If this is received within two months, the hearing will be held within another two months.