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Taxation

Goodness. Shock! We’re praising the ATO. That’s not like us!!!

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It probably had to happen at some stage! For all the criticism we direct at the ATO (all warranted) there had to come a time when we could direct some praise!

You’ll be aware of our intense campaigning against the ATO for bad treatment of small business people. We’ve now had a very good experience, however.

ATO Independent Review

Last year, in partial response to the media coverage of bad ATO behaviour, particularly the Four Corners program ‘Mongrel Bunch of Bastards’ the ATO started a trial ‘Independent Review’ process for small business disputes.

We have just finished supporting and assisting a small business person through this process. We can’t mention the case or specific details but this person accepted that he owed the ATO money. The dispute was over how much was owed. The ATO was claiming about three times the amount we assessed he owed. There wasn’t any tax avoidance or attempt to avoid, rather a series of situations that led to a debt.

We have been involved with many ATO internal ‘alternative dispute resolution’ processes over several years. Frankly, until now, we’ve found these processes to be ‘con-like’ where the ATO used the processes to press their massive superior power and to ‘cook small business people slowly’.

This Independent Review process has been totally different. We found the process genuinely independent and focused on the facts of the case. That’s all we’re asking. The ATO officers did not play any power games or spin, mislead or seek to lie to us and the person we were supporting. The ATO officers were firm, diligent and, yes, nit-picky in seeking factual evidence. And that’s what we’d expect and ask from the ATO officers in doing a professional job.

The outcome is that the small business person won some points but lost others. That’s not unreasonable. Some of the issues in dispute were quite involved. What we were impressed with was that the review was a genuine review. We praise the ATO officers who conducted the review and the senior officers who are directing the process. This is a very big step in the right direction. We hope this continues and moves forward.

But one good experience does not dampen our campaign for major ATO reform to be implemented through legislation. We’ll explain this in future news alerts.

ATO aggression against whistleblowers

One of the ATO’s behaviours that must change is its abuse of whistleblowers. The Age/SMH have a major feature today on Richard Boyle who faces 161 years in jail for telling the truth about the ATO’s abuse of small business people. Richard’s story is covered on the ABC’s 7.30 Report. It’s worth watching.

ATO exposed again! Systemic mistreatment of small business people

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It doesn’t seem to stop. The ATO continues to deny that it does anything wrong, but official reviews and reports keep slamming the ATO. We listed in early April this year the string of parliamentary and other reports calling for urgent reform of the ATO.

This time it’s the Small Business Ombudsman reporting on the ATO’s enforcing debt even while the debt is being challenged in the Administrative Appeals Tribunal. The report finds that the ATO does this on 12 per cent of occasions. This destroys the small business and their ability to challenge the alleged debt. The Ombudsman severely criticizes the ATO and calls for legislative reform.

Here are the Ombudsman’s:

The report refers to

  • “…an inconsistent and undisciplined approach to debt collection by the ATO.”

And quotes an anonymous submission from a current ATO employee saying

  • “The imbalance of power and unconscionable conduct of the ATO leads most to relent as they don’t have the resources to continue.”

The Ombudsman calls for legislative reform to require “mandatory external oversight”. We totally endorse the Ombudsman’s call.

A year ago we released one of our reports on the ATO calling for reform—The Power to Audit is the Power to Destroy. We called for:

  • The ATO to be divided into two separate authorities, one for tax collection and auditing; the other for objections and appeals.
  • The Commissioner-with-all-powers concept be changed, so that each authority is headed by a CEO answerable to a board. (Similar to ASIC, ACCC, etc.)
  • A Small Business Tax Tribunal to be established.
  • Transparency to be required on actual debt and prosecution management.
  • Disputed debts cannot be collected until disputes are settled.
  • Capping of penalties.
  • Judicial oversight of ‘fraud’ action.
  • Strengthening of the Administrative Appeals Tribunal.
We’re delighted that the Morrison government has implemented the Small Business Tax Tribunal and that Labor has endorsed this. But we need this locked into legislation. This new Small Business Ombudsman report strengthens the need for legislative action.
After this election, whoever governs, legislative reform of the ATO must be an item high on the agenda. The integrity of the tax system relies on tax collection being fair and being seen to be fair.

ATO – Mongrel Bunch of Bastards – one year on

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It is one year to the day since the Four Corners show ‘Mongrel Bunch of Bastards’ was aired. This ABC production exposed the ATO’s mistreatment of small business people. Watch the show here.  It continues to be relevant.

So, what has happened in 12 months?

Still the ATO publicly denied any problems. Then Federal Labor called for reform to the ATO’s internal procedures. This was an important step forward.

However, while still continuing to deny problems the ATO:

  • Made significant changes to key personnel.
  • Effectively implemented the ALP’s call for a new internal review processes through an ‘Independent 2nd Commissioner’.

Most importantly

  • The Morrison Government established a new Small Business Tax Tribunal which is a breakthrough for small business people. And the ATO has cooperated in the fairer structure of this new tribunal.

We’re not really that interested if the ATO wants to maintain its ‘nothing to see here folks’ approach. It can continue whatever media line it chooses. What’s important is whether there are fairer treatment processes in place for small business people. And there are—both through the Small Business Tax Tribunal and through the new ATO internal review process. But both these processes need to be tested to see if the practice matches the conceptual design.

There is more to be done. We can expect that the ATO ‘willow tree’ will bend back into shape if the ‘winds’ of media and public scrutiny stop blowing. We must work hard now to get the Small Business Tax Tribunal and other measures locked into legislation. This will take several years of effort.

The ‘What’ and ‘Why’ of the ATO small business reform

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We wrote yesterday to thank the many players involved in efforts to reform the ATO’s treatment of self-employed, small business people. Today we explain what that reform is and why it’s important.

The reform is the creation of the Small Business Tax Tribunal (SBTT) that started on 1 March. It’s a division within the Administrative Appeals Tribunal. There are two key documents to understand:

The importance is that for the first time there will be some balancing of the current massive power imbalance between the ATO and small business people.

The ATO wields total power over the self-employed in the processes of tax assessment, appeals and enforcement. The outcome is that the ATO effectively runs a kangaroo court system which, in our assessment, uses process and legal trickery. In doing this the ATO is unanswerable and unaccountable. This is the core reason for the abuse and mistreatment of small business people evidenced during 2018 in the media and in parliamentary and departmental inquiries and reports.

The Small Business Tax Tribunal is intended to (and should to some degree) ‘even out’ this power imbalance. Note, that there is no change to the legal obligations of people to pay tax or the right of the ATO to enforce those obligations.

The key important reform features are as follows:

  • The SBTT is external to, and independent of, the ATO.
  • Small business people can trigger a referral to the SBTT at any time in their dealings with the ATO.
  • The ATO will not enforce a debt while a matter is before the SBTT, except in extreme cases.
  • The ATO will not ordinarily use external lawyers. If they do use external lawyers, they will fund the small business for lawyers to the same amount as the value of the lawyers the ATO uses.
  • The SBTT will give a decision within 28 days of a hearing.
  • If the ATO appeals an SBTT decision to the Federal Court, the ATO will fund the small business person’s lawyers.

It is important to note that the SBTT has not been created by legislation. We hope that legislation will follow. But at this stage the ATO has agreed to this levelling of power. We have to take this as a mark of goodwill by the ATO and a genuine intention by it for fairer treatment of small business people.

There’s more to be done, however. The ATO can use internal lawyers without funding the small business person’s lawyers, thereby retaining a power advantage to them. But we’re moderately hopeful that this too might be addressed.

Here’s the practical reality of small tax disputes. The bulk of issues are factual. For example, is a claimed expense a genuine tax deduction? For the most part these can be sorted sensibly without lawyers in the SBTT. Lawyers too often get in the way of such practical investigations (apologies to our lawyer friends!) Often, of course, tax law can be complex and lawyers are needed. For example, when is someone ‘working for a result’? Here interpretation of legislation and case law is needed (unfortunately).

The importance of the SBTT is that:

  • It limits the use of lawyers.
  • Where lawyers are needed, the small business person will have equal representation.

As stated above, more is needed, but what has been achieved so far is a big step to a fairer system and one that can be seen to be fair.

Tomorrow we’ll inform you of a major development on the ABN and contractor definition front.

Watch out! Here comes a cascade of thanks. Major ATO reform for the self-employed seems to be here

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Okay, get ready for it. In this update we’re going to praise a lot of people.

The reason is that it’s looking as though the sort of reform we need from the ATO in its treatment of small business people is actually happening. See this article in today’s Australian.

It’s all to do with this document released on the ATO’s website last Friday (22 March). Frankly, we’re surprised how far this is developing. We’ll explain this in detail tomorrow with the key being the operation of the Small Business Tax Tribunal.

But today we’re going to congratulate the players in this process of change. There’s a lot of them. And it’s almost a study in how an effective democracy works!

From about 2015 we’ve been gathering case studies of small business people who’ve been badly treated by the ATO. We started publishing their stories and analysing the ATO’s tactics. See here.  This was picked up by mainstream media, in particular by Robert Gottliebsen (The Australian) and Adele Ferguson (Fairfax/ABC) and then the team at Four Corners (ABC). After the Four Corners show ‘Mongrel Bunch of Bastards‘ (April 2018) the stream of media stories about the ATO’s small business mistreatment became a flood.

Parliament became involved. A string of Parliamentary hearings had the ATO being called to answer. Mistreated small business people gave evidence. The Coalition Government commissioned departmental inquiries. These provided detailed ‘inside’ analysis. The ALP responded by calling for ATO reform and proposed a model for change. Again, see here.

To this point, until late 2018, the process had involved substantiating that the ATO mistreats self-employed, small business people.

Who to thank?

  • Those courageous small business people prepared to have their stories told in public. These include Rod Douglass, Peter Fortunatow, The Pike family and their ABN contractors, Michael Shord, Helen Petaia and more. They prove the point that bad things happen if good people don’t speak out. Good on the good people!
  • The Fourth Estate – Robert Gottliebsen, Adele Ferguson, the Four Corners team and the many journos at ABC, Fairfax and News; Ross Greenwood (Macquarie Radio), Ten News, Radio Cairns, Smart Company, Leon Byner (Radio 5AA) and more. Let’s be clear. Without the persistence of these quality Fourth Estate players, this change would not be happening.
  • The many nameless ATO people who privately told us the truth. Massive thanks and admiration to ATO whistleblower Richard Boyle. He’s been prepared to have his career trashed for the sake of the truth. He’s a real hero and he needs justice from the ATO.
  • The Federal Parliamentarians. Lots of them, but particularly MPs Chris Bowen (ALP), Andrew Leigh (ALP) and Jason Falinski (LP), as well as Senators David Leyonhjelm (Liberal Democrats), Ian Macdonald (LNP) Louise Pratt (ALP), Jim Molan (LP), Eric Abetz (LP) Kristina Keneally (ALP) and many more. Yes, our parliamentarians do work hard and are concerned about the state of our society.
  • Government agencies with the absolute standouts being the Inspector-General of Taxation under the leadership of Ali Noroozi and the Small Business Ombudsman under Kate Carnell. Their research and reports have been essential to the establishment of the facts.

All these groups/people ensured that the truth was researched and exposed. Highly important was Shorten’s Labor announcing that ATO reform was needed. This meant that the issue was not party-political divided.

Then the Morrison government took action (February 2019) announcing the establishment of a Small Business Tax Tribunal and that it would start on 1 March 2019. This was a huge step. Tomorrow we’ll explain the details and why it’s so significant. But special thanks and congratulations must go to Small Business Minister Michaelia Cash and Assistant Treasurer Stuart Roberts. Achieving this reform without legislation has without doubt required a massive effort of behind-the-scenes persuasion within the federal bureaucracy. This is real leadership!

Big thanks also to the ATO. Evidence so far is that there is a ‘sea change’ in attitude occurring within the ATO. The big ATO cultural problem toward small business in the ATO looks like it is being addressed. Have no doubt. This would not be occurring without the full backing of Tax Commissioner Chris Jordan. The journey has begun. We’re hopeful, but cautious. Follow-through and substance both matter.

More tomorrow…

ATO Executive ‘Not Guilty’– Credible evidence that ATO audits are ‘wrong’

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Last week top ex-ATO official Michael Cranston was found not guilty of misusing his position to benefit his son who is on separate charges of alleged tax fraud.

In his defence Mr Cranston said that the actions he took in relation to his son were no more than what he had done for other taxpayers on hundreds of occasions. That is, that tax audits were often so bad that he had to intervene to stop injustice against taxpayers.

Mr Cranston’s evidence confirms what we have been saying for years—namely, that the ATO audit process, outcomes and appeals are systemically bad and flawed. Mr Cranston had to fix bad audits for high-wealth individuals. But our experience and other evidence (see Four Corners) strongly suggest that wrong audits are imposed on small business people and that the ATO has no internal ‘white knight’ to fix bad audits suffered by small business people.

In his evidence Mr Cranston stated that tax audits frequently treated taxpayers badly and that there was a cultural problem inside the ATO. Media quotes are as follows

  • “I was always looking out when my auditors went a bit too far which happened often.” (The Australian, 5 Feb 2019)
  • Mr Cranston said he was concerned about the correct application of tax law, and was “always looking out” for examples of when tax office employees were “too aggressive.” (SMH, 4 Feb 2019)
  • Cranston said he was concerned about “the culture (ATO) side of it” and wanted to know what area was treating taxpayers “like this.” (Goulburn Post, 4 Feb 2019)
  • Mr Cranston had referred to him “hundreds of times” where he feared the tax office had been too aggressive… (AFR, 8 Feb 2019)
  • Bruce Collins, who ran the ATO’s Technical and Case Leadership team handling complex tax matters until he retired in April 2017 told the court: “Michael’s job was to make sure that the wheels didn’t come off and embarrass the tax office” (The Australian, 18 Feb 2019)

Mr Cranston’s evidence is effectively that of a highly credible quasi-whistleblower who operated at the very top levels of the ATO and knew the truth about the bad audits inside the ATO.

This exposes as misleading the denials by the ATO of the existence of a problem—even denials under Senate questioning. Evidence from Mr Cranston’s trial is that the ATO’s concern is to avoid adverse publicity for the ATO. Where, we ask, is the ATO’s concern for truth and the correct application of tax law and treatment of ordinary taxpayers?

The government is moving to implement quickly a fix for the ATO’s mistreatment of small business. But this week we note that the draft design of the Small Business Tax Tribunal put forward by the Canberra bureaucracy will neuter its effectiveness and enable the ATO to continue its bad ways. (The Australian, 18 Feb 2019.) We will say more on this shortly.

Thank goodness. Morrison Government is DOING, rather than just promising, ATO reform

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Usually, in the lead-up to elections, governments make all sort of promises in the hope that this will give them favour with the electorate. But we’re delighted to report that with small business tax reform the Morrison government is delivering, not simply talking.

Today the government announced that the Small Business Tax Tribunal will start up on the 1 March 2019—just two weeks away. This is huge. We continue to see bad ATO small business audits and an ATO incapable of quickly fixing glaring audit errors. It’s an audit system of considerable incompetence, with small business people the victims.

It’s fabulous to see the government responding quickly and with a practical solution to start up immediately. In other words, this is not just an election stunt—it’s real reform.

The key features of the reform already known include:

1. Tax concierge service through the Small Business Ombudsman.

2. 10 tax clinics through Universities to assist small business people.

3. ****A dedicated Small Business Tax Tribunal (SBTT) operating within the AAT. The SBTT will:

    • Be totally separate from ATO.
    • Generally NOT involve lawyers.
    • Appoint a case manager to support the taxpayer.
    • Make decisions within 28 days of a hearing.
    • Require a payment of $500 from the taxpayer for each appeal.

Today’s announcement supplies some additional information:

  • ABN cancellations will be appealable to the SBTT. This gives us an independent review process for the first time.
  • If the ATO uses lawyers, the ATO must pay for the self-employed person to have ‘equivalent legal representation’. This is important because it balances the overriding power/resources of the ATO.

We entirely endorse and congratulate the Morrison Government on the decision to set up the Small Business Tax Tribunal immediately. This is a huge plus for self-employed, small business people.

Details of our campaigning and the history and issues related to the ATO’s treatment of small business people are here.

China and the ATO – Dictatorship vs the Rule of Law

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Yes, we have focused heavily on seeking reform of the Australian Taxation Office in recent times. But the issue is not simply about tax revenue. It’s much bigger. It’s about the rule of law. In this longer-than-normal communication we explain what motivates us by drawing some parallels between China and the ATO.

We start with a story of an acquaintance who does business in China who lamented a recent bad experience. A disgruntled client wanted a refund and penalties to which the client was not entitled. The client had police raid our acquaintance’s office, seize computers, detain a director and scare the life out of staff. She is now unable to leave China.

Throughout this process there’s been no independent court involvement, no ‘rule of law’. This story should not surprise.

Ex-Premier of China Zhao Ziyang would aptly describe this as the ‘rule of man’ as opposed to the ‘rule of law.’

Zhao was the ‘make it happen’ economic reformer under paramount leader Deng Xiaoping’s opening up of China in the 1980s. Zhao, however, incurred Deng’s anger for not supporting the 1989 massacre of the Tiananmen Square pro-democracy protestors. Zhao spent the following years until his death under house arrest. He kept secret diaries revealing the inner workings of the Chinese Communist Party.

Nothing has changed in China since. It is ruled by dictatorship—largely the legacy of Deng Xiaoping. Economic development is pursued on the condition that dictatorship prevails. The story told above is indicative of such a regime. The rule of law does not operate.

Dictatorships operate through cascading patronage. The supreme ruler allocates power to those below through interpersonal relationships. Our business acquaintance was unfortunate enough to have a vindictive client who personally exercised the power of the state within this complex chain.

China has proven that massive economic growth can be achieved under a dictatorship. The downside is that business activity is fraught with major risk. If an individual falls foul of a powerful person or group, they are squashed. Zhao Ziyang’s ‘rule of man’ prevails over ‘rule of law.’

In Australia, we pride ourselves on a tradition which is founded on the operation of democracy and the rule of law. That is, ‘the people’ rule within defined and enforceable rules. Theoretically, all individual power is constrained. The rules-based system is supposed to prevent the abuse of power experienced by our acquaintance in China.

But Australians should not be smug. Democracy and the rule of law are not complete. Elements of dictatorship exist and do oppress individuals from time to time. Perhaps the starkest example is the Australian Taxation Office, whose power and behaviour received concentrated media exposure in 2018.

Under taxation law, the Tax Commissioner is effectively a ‘tax dictator’ exercising all power. The Commissioner’s power cascades under professional privilege to individuals in the ATO.

The ATO can and does raid people’s homes, takes computers and documents, takes money from their bank accounts, detains persons and stops them leaving Australia. This is done without the ATO having to prove that a debt is actually owed. The ATO only needs to form an opinion of a debt and that ‘opinion’ is enforceable.

Oversight of the ATO by the judiciary is strangely twisted. Take one example. Why would a court rule that the ATO did not have to produce a document in its possession which a taxpayer claimed proved their innocence? This happens because the judiciary reviews cases within the framework of the Tax Commissioner’s formidable powers. If legislation states that the ATO can behave this way, the judiciary simply confirm this.

To the ordinary person this is a perversion of the rule of law as ordinarily understood.

Major media coverage of the repeated abuse of small business people by the ATO has triggered political recognition of a problem. Small business people have effectively been bankrupted by the ATO—even where the ATO subsequently admitted no debt was owed.

But although moves are afoot to extend the ATO’s already extensive powers, both the Morrison Coalition government and the Shorten Labor opposition have said that change is needed. Labor says that change can occur within the ATO. The Government has announced that a separate, independent tribunal for small business people will provide checks against ATO abuse. It’s an effective reform step which the government plans to implement quickly.

What the ATO example reveals is that democracy and the rule of law can never be taken for granted. Even in Australia we must constantly work against those aspects of overbearing power within our systems.

Where the rule of law prevails over the ‘rule of man’, stronger, more resilient societies and economies should emerge. Where even ordinary persons can engage in business confident that the risk of abuse by powerful individuals is constrained, they will engage in more business. This creates social and economic strength. That’s what we’re campaigning for.

If you’re particularly interested in following through this issue, this 2001 speech by then-Chief Justice Murray Gleeson is worth reading.

In part, he says:


As an idea about government, the essence of the rule of law is that all authority is subject to, and constrained by, law. The opposing idea is of a state of affairs in which the will of an individual, or a group, (such as a Party), is the governing force in a society…

In Australian legal and political discourse, a governing authority could not satisfy the requirements of the rule of law merely by being able to point to a fundamental law which empowered it to act in an arbitrary manner….

Suppose legislation created an office of Tax Collector, and decreed that every person who derived income should pay to the Collector such percentage of that income as the Collector, in his or her absolute discretion, with uncontrolled power to discriminate, might think fit. That would be a tax. But would it be a law, within the meaning of a Constitution which assumes the rule of law?

ATO refuses internal corruption probe. Anti-Corruption Commission needed

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This week ex-Deputy ATO Commissioner Michael Cranston arrived at court for the start of his trial for allegedly using his office with the intention of dishonestly obtaining a benefit for his son.  Cranston was the top tax official in charge of high-wealth individuals. His trial forms a backdrop to questions about the integrity of the Australian Taxation Office.

We’ve raised questions as to whether the ATO suffers from internal corruption. In September last year we released a major report on a special deal handed to high-wealth individuals in 2013. The deal was organised by then-Deputy Commissioner Michael Cranston, with a loss of tax revenue estimated as high as $4.3 billion. There are calls for a high level inquiry.

We’ve tried to work ‘inside the system’ for an inquiry to occur.

  • First, we wrote to the Australian Commission for Law Enforcement Integrity. This Federal Authority is supposed to hunt for potential corruption in the Federal Public Service. The Commission wrote back to us saying they don’t have the power to investigate the ATO. They suggested we contact the ATO’s internal anti-corruption unit.
  • On 5 November last year we lodged a request with the ATO’s internal fraud unit to conduct an investigation.

For the first time, we can now reveal the response we received on 20 December 2018. The response was from the Director of the Fraud Prevention & Internal Investigations, ATO Corporate and reads as follows:

“It is acknowledged that these issues have been aired with the ATO on previous occasions and it is understood the ATO has provided a response to yourself in relation to these matters.

On this basis, the FPII has concluded that it will not be investigating these matters that have been the subject of previous correspondence with your organisation and yourself personally.”

We replied the same day:

“These matters have NOT been aired between ourselves and the ATO and they have NOT provided a response in any form…. These matters cannot be dismissed lightly.”

Our conclusion is that the ATO cannot be trusted to conduct a proper, or even any, inquiry into serious matters of potential corruption within the organization. This is an extraordinary situation that cannot continue.

Fortunately, the Federal Government has announced that a new Commonwealth Integrity Commission will be established. This will be able to investigate potential corruption within the ATO. We urge that this new Commission be established quickly. We will refer our report on the ATO to the Commission as soon as it is established.

HUGE breakthrough for small business – ATO reform

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Late last night the news broke of the Morrison government’s decision to create a Small Business Tax Tribunal. Robert Gottliebsen in The Australian has scooped the story.

We launched a campaign in February last year for a Small Business Tax Tribunal. Obviously, we are hugely pleased to see the Morrison government take this initiative for fair treatment of small businesses.

If small business and self-employed people are to thrive and contribute to our society, the tax collection system must not only be fair but be seen to be fair. Unfortunately, the evidence is overwhelming that the Australian Taxation Office has been abusing its massive powers. It’s a bureaucracy out of control. This is bad for the rule of law, bad for democracy and bad for justice. The public service exists to serve the people, not abuse the people!

It is fair to guess that the dysfunctional politics of the last decade has enabled the federal bureaucracy at the ATO to push a self-interested power agenda. This is to be expected when ‘the people’, through their political representatives, are not directing the bureaucracy closely.

But the Morrison government has stepped up and in this initiative is acting as a government should. The PM is introducing a sensible first-level ‘check and balance’ against the ATO’s unrestrained powers. This is not about reducing tax collection capacity. Rather, it is about creating better efficiency and limiting abuse. In order for tax collection to operate well ‘the people’ must have faith that the system is administered fairly!

The Small Business Tax Tribunal will enable small business and self-employed people (that is, individuals) in dispute with the ATO to:

  • Go to the Small Business Ombudsman for practical help, then
  • Lodge an appeal with the new Small Business Tax Tribunal. It will be outside the ATO and part of the Administrative Appeals Tribunal system. That is clearly independent!
  • *No lawyers will be allowed, including ATO lawyers. This is the important bit. At the moment the ATO plays a very hard ‘lawyer game’ in disputes. This puts the ordinary person at a massive disadvantage. With no lawyers involved, the focus can be on the facts.
  • A small lodgement fee will be required (around $500).

There’s a lot of detail still to be sorted. We will be following this closely and will seek to make active input on the detail. We hope the government will establish the new Tribunal before the next election.

Just a note: If you think that there aren’t many tax disputes, in just one year, 2012-13 for example, the ATO issued 85,000 garnishee notices (that is, forced payment of alleged debts).