3.1 Through the investigations of complaints and submissions to this review, the IGT has identified a number issues involving ATO accounting systems including the following:
- the crediting of unpaid PAYG instalments in a taxpayers’ income tax assessment;
- ATO correspondence not being received;
- multiple Activity Statements being issued for past periods; and
- the delay in processing ‘wash ups’ of duplicated instalment liabilities.
3.2 This chapter explores the above issues and their underlying causes to identify potential solutions.
3.3 As stated in Chapter 2, the crediting of unpaid PAYG instalments in income tax assessments, leads some taxpayers to believe that they have fulfilled both their income tax and PAYG instalment obligations upon making the required payments as indicated on the NOA. As a result, such taxpayers are surprised when the ATO commences debt collection action at a later date to recover the unpaid instalment amounts.
3.4 As mentioned previously, the ATO uses two different types of accounts for each taxpayer to administer the PAYG instalments system, namely, the ICA and the ITA. Each account has different accounting rules, for example, in the ICA, GIC is calculated on the ‘running balance’ whereas GIC is calculated on individual postings in the ITA. One of the reasons for the different accounting rules is to simplify the administration of the different tax liabilities. The ITA is used to administer income tax liabilities whilst, other tax liabilities such as GST and PAYG instalments are maintained on the ICA.
3.5 Upon lodgment of an income tax return, legislation mandates that a credit equal to the total amount of PAYG instalment liabilities that were accrued during the financial year be posted on the individual’s ITA.64 This crediting process occurs regardless of whether the PAYG instalments were actually paid. Any unpaid PAYG instalment amounts remain as a recoverable debt on the ICA. Such an approach avoids problems with trying to attribute payments made on the ICA to the different tax liabilities as well as identifying which liabilities remain unpaid and accruing GIC against which recovery action may be taken.
3.6 Following an income tax assessment, an NOA is issued to the taxpayer. It identifies any credit that was given for PAYG instalment liabilities, however, it does not specify which instalments have been paid.
3.7 In some cases, the ATO may provide a statement of account along with the NOA when the account balance is different to the outcome of a taxpayer’s assessment.65 A statement of account can be used to reconcile outstanding debts.66 However, it should be noted that such statements are limited to the account to which they relate, for example, unpaid PAYG instalment amounts are identified on an ICA’s statement of account but not an ITA’s statement of account.
3.8 In investigating complaints, the IGT has observed that many taxpayers were of the view that the ATO had incorrectly commenced debt recovery action against them for unpaid PAYG instalments as their latest NOA provided an overall net balance for income tax liabilities with no unpaid amounts identified. After the relevant accounting processes were explained to these taxpayers, they believed the ATO was at fault for not offsetting the unpaid instalment amounts against the credit that was given on their NOA or alerting them to the fact that unpaid PAYG instalments were needed to be paid in addition to any amounts identified on the NOA.
3.9 Generally, BAS and tax agents are aware of the above issues and they seek to address their client’s confusion. However, they believe that this creates some tension in their relationship with their clients and they cannot recover the cost associated with resolving the confusion. Furthermore, as demonstrated in complaints to the IGT, many affected taxpayers do not use tax agents.
3.10 In the IGT's view, as long as two different sets of accounting rules are used to raise, credit and reconcile PAYG instalments and income tax liabilities, many taxpayers will continue to be confused resulting in unnecessary compliance and administrative costs. The use of a single accounting methodology is the ideal solution but it would be a long term goal as it would require significant changes to ATO systems and private sector practice management software.
3.11 As an interim solution, the ATO could apply, or offset,67 unpaid PAYG instalments to the total amount of income tax determined once the lodged tax return has been processed. This is easily achievable for those taxpayers who do not have any other tax liabilities on their ICA. Accordingly, such taxpayers could be informed of their net balance positions by their unpaid PAYG instalments amounts appearing on their NOA as recommended in Chapter 2.
3.12 In addition to providing a net balance position as described above, the ATO could alert taxpayers and/or tax or BAS agents that there are unpaid PAYG instalment liabilities via the prefill service. For example, for taxpayers who use the myTax service, the ATO could prompt the taxpayer to the existence of unpaid PAYG instalments before they lodge their income tax return. Such a prompt could be made by accounting for unpaid instalments on the myTax ‘estimate’ page and providing a pop-up screen which requires the taxpayer to acknowledge that these amounts will need to paid in addition to any refund or debit resulting from their income tax assessment.
The IGT recommends the ATO:
- consider using a single accounting method for administering the income tax regime including the PAYG instalments system as a long term goal; and
- alert taxpayers and/or their tax or BAS agents to their unpaid PAYG instalment amounts through pre-filling and inform them that such amounts must be paid irrespective of any refund or debt arising from their income tax assessment.
The implementation of a single accounting method will be subject to corporate funding and current priorities.
The critical driver of a wash-up is activity statements that have not been lodged when the Income Tax Return is processed. Whether or not the instalment itself has been paid does not impact the requirement to process a wash-up manually to correct the clients account. Therefore to address this issue we have developed a prefill report (also available via ATO’s online services for Agents), which advises clients of the amount of PAYG instalments raised and any that have not yet been lodged, that is, that would trigger a need for a wash-up. The ATO is exploring ways to broaden this for all clients with PAYG instalment obligations.
3.13 Stakeholders have expressed concern that some taxpayers do not receive any ATO correspondence advising them of their entry into the PAYG instalments system. The first notification these taxpayers receive is by way of a debt notice from debt collection agencies or where their bank account is garnished by the ATO, sometimes many years after the instalments liability was raised. In some cases, taxpayers initially thought that the ATO must have made a mistake as no mention of such debts had been made when dealing with other tax matters with the ATO. Furthermore, having raised the issue, ATO staff have been unable to explain the origin of the debt.
3.14 The IGT’s investigation of complaints uncovered that the main cause of taxpayers not receiving PAYG instalment correspondence is that the ATO had used an incorrect or outdated address for them or their nominated representatives. The address used for these purposes is sourced from the taxpayer’s ICA. Activity Statements and debt-related correspondence are sent to the same address.
3.15 In the above complaints investigations, correspondence was sent to outdated addresses where the ATO:
- had changed the taxpayer’s address on their ITA but not their ICA;
- had not refreshed the taxpayer’s address details on their ICA when they re-enter the PAYG instalments system; and
- was unable to update the taxpayer’s address in the ICA as their accounts were inactive at the time.
3.16 Another cause of taxpayers not receiving ATO correspondence is because they had opened an account on myGov and linked that account to the ATO. As a result, PAYG instalments correspondence is sent electronically to that account. This issue is broader than the PAYG instalments system and it has been explored by the IGT in the past.68 In these cases, a taxpayer may set up a myGov account and link it to the ATO but may never use it again, at least for tax purposes, forget they have such an account and/or not inform their tax or BAS agent. In the meantime, they or their tax or BAS agents no longer receive correspondence via their previously nominated channels. It has also become a source of tension between tax or BAS agents and their clients who may perceive that the agent has received the correspondence but has been negligent in taking action or informing them.
3.17 The last major reason for taxpayers not receiving correspondence was due to electronic lodgments by tax practitioners which override any preferences set by the taxpayer. This has occurred even where tax practitioners were not engaged to assist with their client’s PAYG instalment obligations.
3.18 As explained in Chapter 1, the ATO issues its welcome letter to the address listed on a taxpayer’s ITA system account. However, Activity Statements are sent to the address listed on the ICA account of the taxpayer.
3.19 In 2012, an own motion privacy investigation by the Office of the Australian Information Commissioner (OAIC), brought to the ATO’s attention that Activity Statements were being sent to outdated addresses.69 During the OAIC investigation, it was noted that if a taxpayer informed the ATO that their address had changed on their income tax return, the ATO Information Technology (IT) systems would only update the address listed for their ITA and not their ICA.70 Hence, Activity Statements, containing confidential information, could be sent to an old address where the taxpayer no longer resided. The ATO sought to correct this issue by introducing a process for reconciling addresses71 on the two accounts.
3.20 As a result of the inclusion of the new process, new entrants to the PAYG instalments system, who have not previously held an ICA, have their postal addresses on the ITA exported to their ICA.72
3.21 For new entrants that hold, or previously held an ICA, the ATO attempts to determine whether the ICA address is current. To do so, the ATO determines whether the taxpayer has an active Australian Business Number (ABN) and if so, whether the address recorded on the Australian Business Register (ABR) matches the address on their ICA. If the addresses are matched, the ATO systems will continue to use the address recorded on the taxpayer’s ICA for PAYG instalments correspondence. Where there is no match, the ATO systems will import the address used on the taxpayer’s ITA to their ICA.73
3.22 For taxpayers currently in the PAYG instalments system that have the same address for both their ITA and ICA, when an income tax return is lodged that provides a new address, both addresses will be updated. If the taxpayer has different addresses listed on their ITA and their ICA, the ATO’s system will only update the address on the ITA. Such an approach allows taxpayers to have different preferred addresses for correspondence regarding different tax obligations.74
3.23 In 2013, the ATO had also identified issues concerning the manual updating of taxpayer addresses. In particular, the ATO Complaints Unit found that where taxpayers or their representatives telephoned the ATO to update addresses, ATO staff would only change the address on the taxpayer’s ITA. However, taxpayers and their representatives had assumed that all their addresses for dealings with the ATO would be updated. This resulted in situations where the ICA addresses were not appropriately updated and led to complaints about recovery action being taken without prior notification of existence of the corresponding debt.75
3.24 As a result of the above, ATO scripting now requires staff to check with callers which addresses are to be updated and the reasons for updating.76 Accompanying guidance explains the need for these questions to be asked.
MyGov and tax agent lodgment
3.25 When taxpayers link their myGov account to the ATO, the screen asking taxpayers to accept the ATO’s terms and conditions requires taxpayers to specifically agree to their myGov inbox being used to receive all ATO correspondence, including those that may have previously been sent to their tax or BAS agent. The screen also states that their agent will be able to access correspondence electronically.77
3.26 The ATO’s terms and conditions also stipulate that:
You have designated your myGov account and inbox as your address for the Australian Taxation Office (ATO) to send you correspondence. You will receive a welcome message from the ATO in your myGov inbox to confirm the service in enabled.78
3.27 If taxpayers no longer want their myGov inbox to be the preferred address for ATO correspondence, they can only change this by contacting the ATO by telephone in which case such preference cannot be overridden by providing a different address on subsequent tax returns that they may lodge through the myGov.79
3.28 When a government agency, such as the ATO, sends correspondence to taxpayers’ myGov inboxes, they will be alerted to that correspondence by either SMS or email.80 Such notification is a generic message that does not indicate the type of correspondence or from which government agency it may have originated. Furthermore, only one message is sent per day regardless of the number of correspondence that may have been received.
3.29 As mentioned earlier, if a taxpayer has a tax or BAS agent and links their myGov account to the ATO, no notification is sent to the agent. However, tax and BAS agents, through the ATO’s Client Communication List (CCL), are able to access PAYG instalments correspondence sent to their clients’ myGov account.81 To do so, the agent must log into the CCL and then search for such correspondence using their client’s tax file number.
3.30 Lastly, if a tax or BAS agent representative lodges an Activity Statement via their respective Portals or practice management software, all correspondence is then sent to them electronically by default.82 This will override any separate postal address nominated by the taxpayer, whether that nomination was made by telephone or by accepting the terms and condition in linking their myGov account to the ATO.
3.31 It is important that taxpayers are promptly made aware of PAYG instalment liabilities so that they may fulfil their obligations. Whilst the risk of sending correspondence to incorrect addresses may appear to be small, the resulting impact on taxpayers can be severe, for example, having their bank account garnished. Such action may be viewed particularly unfair as PAYG instalments are a pre-payment of estimated annual tax liabilities and, as observed in Chapter 2, the entire PAYG instalments system is not well understood by the general public.
3.32 Therefore, it is not surprising that those who do not receive any correspondence about their entry into the system feel frustration and initially regard any resulting debt recovery action as an ATO error. Not only is this an undesirable situation for those taxpayers, but it also delays ATO collection of liabilities.
3.33 In 2012, the ATO sought to address the system issues that cause Activity Statements to be sent to outdated addresses. However, as stated earlier, IGT complaints investigations have revealed that such errors are still occurring. These errors are another symptom of using two different accounting methods or systems to administer the PAYG instalments regime. The IGT is of the view that they cannot be fully eradicated until they are replaced by a single system as recommended above.83
3.34 In the meantime, some improvements may be realised through better handling of taxpayers’ requests to update their addresses. Through complaint investigations, the IGT has noted that ATO staff are at times uncertain about dealing with such requests. Whilst ATO scripting indicates that staff are expected to ask taxpayers why they are requesting their address details to be updated, taxpayers may not be aware of the ATO’s two different accounting systems. Without such awareness, taxpayers may respond by saying that they are changing address because they are moving, not knowing they are providing pertinent information about all their tax obligations.
3.35 The IGT is of the view that ATO scripting should require staff to determine whether the taxpayer has an existing ICA and to ask all necessary questions to determine whether the address associated with it requires updating.
3.36 Furthermore, as many taxpayers do not always update their address with the ATO, the ATO should respond to indications that taxpayers may not have received ATO correspondence, for example, when instalment amounts are not paid. In these circumstances, the IGT believes that the ATO should take prompt action to confirm the taxpayer’s address by alternative methods, such as telephone or SMS. Such an approach was previously explored in the IGT’s Debt Collection review.84
MyGov and tax agent lodgment
3.37 The ATO does provide an additional warning prior to an individual completing the myGov linking process to the ATO. However, terms and conditions are frequently accepted without considering the details in today’s online environment.85 Unsurprisingly, the IGT continues to receive complaints where taxpayers have not received correspondence and on investigation the underlying cause is that those taxpayers had linked their myGov account to the ATO without appreciating the consequences.
3.38 The myGov platform also causes difficulties for tax agents, as they are not notified that they will no longer receive instalment notices for their clients when their clients link their myGov account to the ATO. Whilst tax agents are able to review their clients’ correspondence in the CCL, they are not notified to do so after such an event.
3.39 As PAYG instalments correspondence may continue to have the tax or BAS agent’s postal address in the address block of the document, taxpayers may, understandably, form the view that their agent had received the correspondence but had not acted on them. The resulting debt, interest, potential penalties and resulting recovery action may further strain the client-agent relationship and may lead to diminished trust and confidence between the two parties.
3.40 The IGT is of the view that the long term solution would be to implement ATO and myGov systems changes that allow taxpayers to choose their preference for each type of ATO correspondence that they may receive. MyGov notifications should also be improved by sending a notification for every piece of correspondence received, indicating the level of importance, the subject matter and which agency has issued it. However, it is acknowledged that the myGov platform is managed by the Department of Human Services (DHS) and the ATO is limited to what it can achieve on its own.
3.41 The above improvements require significant changes to ATO and myGov systems. In the case of the latter the impact on other government agencies and the user of their services would also need to be considered.
3.42 In the meantime, the IGT believes that the ATO should explore other solutions to deliver improvements more immediately. One option would be for the ATO to engage with DHS to ensure that, on linking of myGov accounts to the ATO, the existing address for correspondence is not overridden where the taxpayer uses a BAS or tax agent.
The IGT recommends the ATO:
- modify its call centre scripting, for dealing with taxpayers’ request to update their addresses, to require its staff to check if a taxpayer has an existing ICA and ask all necessary questions to determine if the address on it needs to be updated;
- where taxpayers have unpaid or unreported PAYG instalments, take prompt action to confirm the taxpayer’s address by alternative means such as telephone; and
- engage with the Department of Human Services and software developers to:
- consider, as a long term goal, providing functionality that allows taxpayers to set address preferences for where they wish to receive different types of correspondence and more detailed notification of any correspondence that has been received in their myGov inbox; and
- ensure that, on linking of myGov accounts to the ATO, the existing address for correspondence is not overridden where the taxpayer uses a BAS or tax agent.
- Work is already underway in this area, including working with the Digital Transformation Agency.
- We will engage with stakeholders to improve myGov’s notification about mail preferences, including improved provision of information about what mail has been sent. The ATO will recommend that these improvements include automatic notification to a client’s BAS or tax agent when an address is updated. We will also progress an improved communication preference tool for tax agents.
The ATO will explore where improvements can be made to call centre scripting.
The ATO already contacts taxpayers, or their authorised representative, using a range of addresses and channels, such as SMS, phone or paper.
3.43 Stakeholders have observed instances where the ATO systems simultaneously issue multiple PAYG instalment Activity Statements each corresponding to a particular past period but with the same due date for payment, adversely impacting taxpayers’ cash flows.
3.44 The ATO has advised the IGT that the above issue occurs where an outdated address for a taxpayer is subsequently updated with hitherto incorrectly addressed ATO correspondence being reissued to the updated address. Correspondence requiring payment are reissued with an appropriate extension to the due date for payment. The length of any such extension is at the discretion of the issuing officer.
3.45 The ATO has also explained that the above issue will occur where the ATO cancels a taxpayer’s ABN, but there is a delay in cancelling their GST registration.
3.46 Voluntary compliance with the PAYG instalments system relies on taxpayers being aware of the payments required and the dates by which they are due so that appropriate budgeting can take place to minimise impact on cash flows. Accordingly, where multiple Activity Statements are received unexpectedly, there is a risk of
3.47 The IGT is of the view that, as soon as the ATO detects that an address may be outdated, for example by its correspondence being returned, it should take prompt action to update that address. Such action could include review of the ATO’s data holdings to locate a more recent address and by attempting to contact the relevant taxpayers, by telephone or other means. Such prompt action would minimise the number of Activity Statements being sent to an incorrect address and corresponding instalments remaining outstanding.
3.48 The ATO does not seem to have documented procedures or policies for dealing with issuance of multiple Activity Statements following an address update. Without appropriate procedures or policies, it would be difficult to determine whether the ATO is consistent in its approach to deferring due dates in these circumstances. Accordingly, the IGT believes that the ATO should develop procedures and policies for these situations and train the relevant staff accordingly. Such policies would also provide clarity on the ATO’s existing process to provide lodgment and payment deferral, including the relevant factors that should be considered.
The IGT recommends the ATO:
- as soon as practicable after it has detected that a taxpayer’s address is outdated, take prompt action to update the address, for example, by attempting to contact that taxpayer by alternatives means, such as telephone; and
- develop procedures and policies for determining the appropriate deferred lodgment and payment dates when issuing multiple PAYG instalment Activity Statements and train its relevant staff accordingly.
The ATO will explore the use of using data and analytics to improve taxpayer address data integrity.
The ATO will look at current policies and procedures and determine if any updates are required. We will also explore further training and education opportunities.
3.49 The ATO systems operate on the premise that Activity Statements are lodged before the corresponding annual income tax return.86 Where this does not occur, the PAYG instalment liabilities relating to those Activity Statements are not reflected in the NOA. As a result, the taxpayer, effectively, would have to pay tax on such income twice unless the relevant PAYG liabilities can be reversed. Such reversal requires ATO staff to manually change the relevant accounts and is commonly referred to as a ‘wash up’.
3.50 Concern has been raised with the ATO’s delay in processing wash ups. Such delay may result in unnecessary debt collection action even though there is no outstanding income tax for the period in question.
3.51 Notwithstanding the ATO’s 28 calendar day service standard for performing a manual wash up, it may take up to three months. In one case debt recovery action had commenced for over a quarter of a million dollars, albeit that such action was subsequently stopped when the wash up was completed.
3.52 It should be noted that the problem is avoided as long as the income tax return is lodged after 21 July which is the due date on the Activity Statement for the fourth quarter.87
3.53 Where an income tax return is lodged before this date, the ATO has an automated process to avoid the need for manual wash ups88 for all annual PAYG instalment taxpayers. This automatic process adjusts the instalment amount to nil once the relevant income tax return is lodged (‘auto-finalise’).89 The ATO also auto-finalises quarterly PAYG instalments for taxpayers who have no other obligations to report on their Activity Statement.
3.54 However, manual wash ups are still necessary for other scenarios,90 for example, taxpayers who are required to report their PAYG instalments and other tax liabilities on a BAS.91 Upon finalising the manual process, the ATO issues correspondence to the relevant taxpayer explaining the actions that had been taken, including crediting the taxpayer for interest on any overpayments.92
3.55 The ATO had previously considered modifying their systems to automatically finalise the PAYG instalments label on a BAS once the due date has passed.93 It was identified that this would eliminate an estimated 7,452 wash up cases and reduce ATO costs by $179,631 in the 2011 year, with increased cost savings in each following year.94 However, this approach was not adopted by the ATO, the reasons for which have not been communicated to the IGT.
3.56 In performing a manual wash up, ATO staff must apply an instalment credit to the taxpayer’s ITA for the correct period. The ATO has assisted staff by developing a macro tool to automate some tasks required to complete the wash up. This tool has reduced wash up processing times from approximately 4 hours per case to 30 minutes.95
3.57 The ATO has sought to address the risk of PAYG instalments being effectively required to be paid twice where the annual tax return is lodged prior to the corresponding Activity Statement(s). However, the lack of a fully automated response has meant that the problem has not been completely eradicated.
3.58 Whilst the ATO’s macro tool to support staff has reduced the time to process manual wash ups to 30 minutes, the ATO’s 28 days service standard has been exceeded and unnecessary recovery action commenced in certain instances.
3.59 The ATO had previously considered auto-finalising the PAYG instalments label in a BAS after the due date had passed. Such an option was not adopted despite the projected cost savings. This would significantly reduce the number of taxpayers affected as well as the corresponding ATO manual processing.
3.60 Similar options may be open to the ATO, for example, any outstanding obligations to report and pay PAYG instalments may be supressed where an income tax return has already been lodged for the same period. If such an option was to be implemented, only quarterly instalment taxpayers, who lodge their income tax return before 21 July, would require a manual wash up. The ATO could also advise these remaining taxpayers to delay lodging their tax returns by, for example, alerting them through myTax or broader TaxTime communications.96
3.61 Where a manual wash up is still required, the ATO should take the precautionary step of preventing any debt recovery action from commencing until the wash up process has been completed. The debt recovery action can be resumed if there is any related debt after the wash up is complete.
3.62 It should be noted that those recommendations in the previous Chapter which are aimed at better informing affected taxpayers about the PAYG instalments system and in particular the consequences of not lodging Activity Statements promptly should assist in reducing the instances of lodging income tax returns before the relevant Activity Statements.
The IGT recommends the ATO:
- for taxpayers who have lodged an income tax return but not lodged corresponding BASs by the due date, automatically supress any obligations to report and pay PAYG instalments for that income tax period;
- for taxpayers who would otherwise require a manual finalisation of the PAYG instalments label, issue targeted communications encouraging them to delay lodgment of their income tax return until 21 July; and
- where a manual finalisation of the PAYG instalments becomes necessary, any related debt recovery action should be delayed pending the completion of this task.
The ATO agrees that eliminating manual wash ups for early lodgers would result in an improved client experience. As noted, the ATO currently auto-finalises activity statements to avoid manual wash-ups for instalment only taxpayers. The ATO is investigating extending this automation to accommodate taxpayers with other BAS obligations not finalised by the lodgment of the income tax return, including the feasibility of revising to nil the BAS instalment obligation for early lodgers. Extending wash up automation will depend on funding, systems capability and the prioritisation process.
In conjunction with work to extend wash up automation, the ATO will also investigate different ways to improve the client experience where a taxpayer has a debt that is due to a wash up situation involving PAYG instalments. Implementation of a solution will depend on system changes and prioritisation.
64 Taxation Administration Act 1953 sch 1 s 45-30.
67 ATO, Offsetting of refunds and other credits against taxation and other debts, PS LA 2011/21, 26 November 2015, p 3: indicates an ATO preference and a legislative requirement to offset such amounts.
68 IGT, Submission to the inquiry into taxpayer engagement with the tax system (February 2017) para 4.45; IGT, Annual Report 2015–16 (2016) pp 4 and 27.
69 ATO, ‘ATO Office Minute’ (Internal ATO document, 1 June 2012).
71 ATO, ‘Emerging Issue ATO Charter & Complaints, Pay As You Go Income Tax Instalment (PAYGI) address updates’ (Internal ATO document, June 2013).
72 ATO, ‘AP353 Service description – Client Contact details’ (Internal ATO document, 8 March 2017) pp 71–77.
74 Above n 71.
76 ATO, ‘Client details – add or modify address’, (Internal ATO document, 5 May 2017).
79 ATO, ‘myGov Link Orchestration AP353 – Service Description’ (Internal ATO document, 11 May 2016).
82 Above n 19.
83 See recommendation 3.1(a).
84 IGT, Debt Collection (2015) p 103.
86 ATO, ‘PAYG instalment Wash-up options’ (Internal ATO document, 21 December 2010) p 1.
87 ATO, ‘PAYGI Washups Option 7’ (Internal ATO document, 10 December 2010) p 3.
88 Above n 86, p 2.
89 Above n 87, p 2.
90 Above n 86, p 2.
91 Above n 87, p 3.
92 Above n 86, p 2.
93 Above n 87, p 3.
94 Above n 87, p 4.
95 Above n 86, p 2.