Mr. Niall Cody:

No, the case is against us. Let us start again. We raise an assessment, the taxpayers appeal it, they go to the Tax Appeals Commission, they put their case and we will put our case, and the Tax Appeals Commission will issue a determination either for them or us, or the determination may well be partly for them and partly for us. However, it will make a final determination and the assessment will either be confirmed, unconfirmed or amended. At that stage both the taxpayer and ourselves have a right to appeal the decision handed down by the Tax Appeals Commission to the High Court. In that case, regarding the Tax Appeals Commission, there is a case stated to the High Court setting out that these were its findings of fact and this is what it determined, and then the case is appealed to the High Court on a point of law.