I have great respect for these gentlemen as well.
The major thing is that our interpretation on the materials provided on Tuesday was that the future legislated tax changes, as corporate tax reductions, were not factored in. That's our interpretation based on the information we have at our fingertips and what we know going forward about tax changes that have been legislated, so that's one of the major things we've highlighted.
As well, I mentioned that we have perhaps a philosophical disagreement on whether or not deferred taxes should be included, and those are worth $80 million. The previous adjustment with respect to legislated tax changes is $232 million, and deferred taxes we estimate at $80 million. We believe, as do many others, including Jack Mintz, who I know has presented evidence on this case, that they should be included.
And the other two really relate to two assumptions with respect to the average effective tax rate and how many of these accounts are held in tax exempt accounts. There are two real divides, but a good chunk of the issue relates to the legislated tax changes and whether they're included or not. That should be knowable just based on data, assumptions, and how the number was calculated ultimately.