Mr. Niall Cody:

Some will agree the tax and the interest but will not agree the level of penalty. To be published the penalty must be in excess of 15%. In many cases the person will not agree the level of penalty. If they do not agree the level of penalty and we feel it is 30%, 40% or whatever the rate is, we have to go to court to get the penalty confirmed. In our publication list one will see some cases where the penalty notification has been imposed by the court. One can identity them in that quarterly list. They will have agreed everything but the penalty and we will have to go to court and prove the case in court. That is some of what is involved.