It's important to understand on that 65% number that a couple of things happen when a file moves from the assessment audit to appeals. In the cases where the appeal is ruled with the taxpayer, only a small percentage of those were because the auditor was seen to have misapplied the law. In a number of cases new information became available; either the taxpayer provided new information or information that was there wasn't realized.
In a lot of those cases new information caused the decision to change. That can happen. That's part of why what we're trying to do is to make sure we deal with cases at the appropriate place, in the assessment audit place, and that only at the appeals are we looking at, not new information coming, but revisiting the decision. That's part of the 65%.