Mr. John O'Callaghan:

I do not think this is a big issue overall. The tax collection system works pretty well. From our point of view, the idea that we have a large number of cases is simply wrong. This came up six months ago or so when the Comptroller and Auditor General was auditing our little operation. That office was interested in a large number of cases which, on the Revenue system, were shown as being under an appeal stop. A really important point to make about something being under appeal is that, when someone appeals an assessment, it does not necessarily mean the person wishes to have a hearing. If a person gets an assessment and does not appeal it within the appropriate time, which is mostly 30 days, the tax becomes payable. What one does, if one gets an assessment, is to appeal it. Some 99.99% of appeals never proceed to a hearing, much as 99.99% of parking tickets never go to the District Court. The ticket is paid. A person may engage in correspondence or whatever else. Similarly, the appeal function is, for most people, merely a way of enabling them to continue to correspond with the Revenue Commissioners and to come to an agreement about the quantum of tax they owe.

What I think has happened is that in the Revenue Commissioners there are a lot of appeals. Someone appeals, the case is under discussion, perhaps the case has been settled, but the appeal stop has not been taken off. When the Comptroller and Auditor General came to us and we showed it the actual number of files we had which were live, the number was tiny. As we said in our submission, the number is perhaps in the low double digits. However, there seems to be some sort of an accounting issue throwing up numbers of taxes under appeal. Of course, "under appeal" refers not just to appeals to the Appeal Commissioners but also appeals to the Circuit Court, the High Court, now the Court of Appeal, and the Supreme Court. To put on record, this is a simple error. We have a tiny number of cases in front of us. If there were any sort of a backlog, I would have anticipated a lot of letters from the Revenue Commissioners and from taxpayers looking for information on the progress of the case. We do not have any such letters. We have no one requesting us to proceed with this case, that case or the other. I am not saying that we do not have a work in progress. However, there is no iceberg-type effect.

I was in two minds whether to put that on the record, but I think it was better to have done it.