Mr. Mark O'Mahony:

When we received the legacy cases, we conducted a detailed analysis of them. For example, the 2,731 cases would have included several appeals by the same appellant over a number of years in which they raised the same issue. We consolidated them into one appeal. Similarly, there were some lead-follower appeals in which perhaps the same tax planning issue was being raised by multiple appellants. We said that rather than have 40 appeals, we would have one.