I'd like to clarify two points. First, subclause 103(2) provides:
(2) The standard of review for an appeal is correctness for questions of law and palpable and overriding error for questions of fact or questions of mixed law and fact.
That's where the idea of consideration comes into play. The idea is to determine the applicable standard. When we say that the applicable standard of review is correctness for questions of law, it's a very strict standard, but the applicable standard for questions of fact and mixed questions of fact and law is palpable and overriding error. Consequently, in such cases, it must really be demonstrated that the Commissioner—