Ms Josephine Feehily:

People settled for a wide variety of reasons. Our ability to raise a tax assessment does not require the same burden of proof as a criminal burden of proof for tax evasion. We can raise tax assessments. In the face of a tax assessment which we would be able to stand up, we are quite content we had evidence that tax was owed. There is a difference between tax being owed and tax being knowingly, wilfully, fraudulently, negligently - and all of those words - evaded, to the point of criminal standard.