There are various levels: the review itself, the appeal hearing, and then there are other procedures for review and appeal, including reconsideration and the judicial review. It could be the Tax Court of Canada. It could be a compassionate award.
I'm trying to get a sense of how you're counting an appeal. If an individual launches an appeal and it goes to the review stage, and then if it fails and the person goes to the appeal hearing, does that count as two separate incidents or as only one incident in terms of calculating the number of appeals that the particular individual has launched? Of course, the individual may go to a third stage of appeal. Is each one counted separately?