I hate to disagree with the commissioner--and she may have been improperly briefed--but in paragraph 4.20 we say:
When it prepared its year-end audited financial statements for 2007 and 2008, the Agency identified some cases in which corporate taxpayers had made an advance deposit because an ongoing audit presented a bona fide risk of reassessment. In most other cases, the Agency concluded that the amount of funds on deposit significantly exceeded its estimates of additional tax that might be payable under future reassessments.
The agency did not indicate any disagreement with the facts. This is their assessment and they agreed with that statement.