Mr. Niall Cody:

In the normal case, we will raise an assessment. The taxpayer usually has 30 days to appeal that assessment to the Tax Appeals Commission, which is independent of us. We are involved in all of the cases of the Tax Appeals Commission because obviously it is a Tax Appeals Commission but it is statutorily independent. As I have said every time I attend a committee, the reform of the Tax Appeals Commission however many years ago has been one of the most positive developments because it has reached the stage that when we raise an assessment the appeal happens very quickly in a matter of months, and that is the time it should happen.