I am informed by the Revenue Commissioners that a single figure for the number of appeals unresolved for a period in excess of ten years is likely to present a misleading picture. This is because the system used by the Revenue Commissioners to record appeals does so by reference to unsettled assessments. Thus, a single issue can give rise to a number of appeals in relation to the same taxpayer. Furthermore, in a number of instances appeals remain open because the matter in dispute is the subject of a test case involving a different taxpayer. The Revenue Commissioners are analysing their records and will provide an update to the Deputy by the end of the month.