Mr. John O'Callaghan:

I am not, to be honest. In Ireland, if one is a taxpayer, one goes for rehearing in the Circuit Court. It is exactly the same as if one were before an appeal commissioner. The hearing is held in cameraand one does not have to be represented. The judge simply rehears the case. If one goes to the High Court, however, it all takes place in public. The position is the same in the Supreme Court. Therefore, one suddenly finds oneself in the limelight if one wishes to pursue one's case on a point of law.

Another minor point is that if a taxpayer wins in front of the Appeal Commissioners on a point of law and if the Revenue challenges the finding in the High Court, he or she could be obliged to pay the Revenue's costs if he or she loses the case. Some barristers would not want to seek costs in those circumstances. However, that is an aspect which might be considered. I have always thought the current system unfair. Where someone wins a case in the first instance and where the Revenue, on a point of policy, wants to challenge the finding, then I do not think the taxpayer should pay the latter's costs in the High Court or the Supreme Court.