We've constructed a situation where if they don't give us the right amount of tax, we are going to charge them interest that's non-deductible and there will be penalties. In this whole thing it's a balance of trying to treat the taxpayer fairly. If our assessments show they did pay too much tax, it seems fair and reasonable that we should pay them either the government's borrowing rate, the rate they would have borrowed at, or what they would have earned as a rate of return. There should be some kind of fair compensation if the government has kept a taxpayer's money that it shouldn't have kept.
On October 26th, 2009. See this statement in context.