Thanks for the question.
I want to be very careful with Ms. Brooks' summary. I will cite from it, but these conclusions are her own. It's not for me to read into her findings. She obviously is looking at tax law, in which she is an expert. She is looking at jurisprudence. She's looking at decisions of the court and how they bear upon her review of it. This is her opinion. I am citing it.
Going back to the remarks I made earlier, each and every case has its own determinative facts. That is why auditors spend hundreds of hours assembling the facts on each and every case to find the right treatment for that case. That's why they work with Justice. Justice understands the law and they're active in understanding the jurisprudence, the decisions, and the risk or benefit of going to court. They have to make that decision on each and every case.
That is why you have Ms. Henderson here and her team. There would have been a team of a few people that worked on this file for many months. They would have been working, seeking legal advice to make an appropriate determination, as we would with any taxpayer.