I think this may be part of the problem. Whyte has already said he wants to draw a line in the sand once the verdict has been reached. If we win, they will appeal which will basically mean going around in circles again, if we win the appeal HMRC will appeal again and again. If we lose the case and get a lowish bill (£5 - 10 Mill) then it gets paid, admin doesnt happen and we win 4IAR but again , the saga is over. If we lose and get a massive bill then we are probably fucked. From what Whyte has been saying, HMRC have been near on impossible to negotiate with so threatening them with us potentially going into administration and getting little or nowhere near the cash they want might make them be more willing to come to a compromise.