I move amendment No. 21 :
In page 26, subsection (2), line 10, after "person" to insert "or that the amount of tax assessed is excessive".
This is to broaden the scope of the appeal because the appeal here relates only to the issue of whether a person is an accountable person or not. This is a case where somebody fails to make a return in the prescribed period and the Revenue Commissioners raise an assessment against him. There is more at stake than the question of whether the person is an accountable person or not. He may have failed to make a return in time because of difficulties he faced, or his accountant might have been on holidays. He should not, because of that, be put into the position that, no matter what amount the Revenue Commissioners levy against him arbitrarily and without any knowledge on their part as to what amount is properly due, he has no appeal against that. Perhaps I am misinterpreting that or misunderstanding it, but it seems to me that there is not any appeal against the amount in question but only on the point of whether he is an accountable person or not. In case I am wrong, I do not want to waste time in developing that point. Perhaps the Minister could clear my mind on that.