Mr. Mark O'Mahony:

We are aware of that as an issue. It was a common complaint in a number of submissions received in our public consultation process. We are constrained regarding what we can do in looking at Revenue conduct. We do not have the statutory jurisdiction to do that. What we can do and have actively been doing, as the Deputy will have seen in the annual report and statement, are case management conferences. They were originally envisaged as a means by which we would give directions. We have been much more flexible and creative in our approach. That is a forum where if there is, as we see it, a genuine difficulty or lack of clarity affecting a taxpayer's ability to form a view as to whether something is appealable, that is an opportunity for us to invite Revenue to clarify its position. The Deputy is right that the scope to extend one's grounds of appeal is quite prescribed by statute. The approach of the TAC has always been that we will be flexible and sympathetic to a taxpayer faced with an assessment where he or she honestly does not know how the figures have been arrived at.