History made as HMRC agrees to pay VAT back to private golf clubs
By Alistair Dunsmuir
After several years of legal wrangling, HMRC has agreed to make substantial payments to hundreds of private members’ golf clubs for overpaid VAT within the next two months.
However, as Golf Club Management predicted last month, the organisation will only pay up to 50 percent of what the recipient golf clubs think they are owed. Some golf clubs will only receive one third of what they believe they are owed.
Discussions over what will happen to the remainder of the money are set to continue for many more months to come.
The case follows the 2013 Court of Justice of the European Union (CJEU) ruling, itself the culmination of years of legal battles, that VAT on green fees at private members’ golf clubs had been incorrectly applied for several years. This meant that scores of ‘not for profit’ clubs were able to claim the VAT back on green fees – believed to be worth several thousands of pounds to many of the venues involved.
HMRC had been reluctant to pay the VAT back but it has now agreed to make interim payments of up to 50 percent of overpaid VAT on non-member green fees at private members’ golf clubs by this April, following an announcement at the Royal Courts of Justice in London.
Discussions between KPMG, which is representing many of the golf clubs involved, and HMRC, will continue about how much extra money should be paid to clubs as HMRC confirmed at the courts that it wishes to invoke a defence of partial unjust enrichment, and if no agreement is reached a further High Court hearing will be scheduled in the summer. HMRC is also due to provide an ‘information sheet’ by February 9, which should give clubs a better idea of how much of a repayment to expect by April.
“HMRC will apply a provisional unjust enrichment restriction to the claims and make an interim payment plus simple interest,” said a spokesman for the GCMA.
“For the majority of clubs, this restriction will be 50 percent of the value of the final claim. For a small number of clubs there will be a restriction of 67 percent of the final claim. Whether a club will receive 50 or 67 percent depends on a number of factors but the higher restriction is likely to be associated with the highest green fees and thereby highest claim value. HMRC will have 30 days to make the interim payment once the final claim amount is agreed.”
By Alistair Dunsmuir
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Just to clarify…Can anyone from the private members club sector actually differentiate the way you generate your income from a proprietary golf club?
Correct me if I am wrong, but don’t we both actively sell green fees, memberships, societies, functions, etc?
In the event of a surplus at the end of a financial year we as proprietary clubs call this a profit! What do private members club’s happen to call this great achievement?
Whatever it maybe called, I suspect it would be used swiftly and effectively…maybe to improve your facilities… or a good reason to keep the subscriptions low to keep the members happy? I ask you, do you think this is fair practice?
Is this process not ‘betterment’….and unfair competition?
Although a member of a private members’ club and an adviser to a number of others, I have to agree that the ruling is unfair. However, that does not mean clubs should be embarrassed about taking it. It will help some clubs out of a black hole, but the wise committees will use it to invest in modernising their operation to better cope with the future by improving their visitor appeal.
As a member of a members golf club i find some of the remarks by some people below as objectionable. Any money returned to any golf club MUST be a benefit to the game of golf in these uncertain times.
Where I am based which is a rural area there are four main golf clubs withing a small area, two of which are members golf clubs both of which are old and established over a period of many years, while the other two are propriety golf clubs which are relatively new, where farm land has been redeveloped into golf courses with extensive government funding. These clubs are like all other propriety golf clubs, where people have invested in a BUSINESS and are generally in the golf world for profit. Which is totally against the principals of a members golf clubs.
I cannot remember when the propriety golf clubs were developed the local members golf clubs complaining about the free money which was handed out to the developers to allow them to enter a “for profit business”. I certainly didn’t see the free money as a level playing field where these clubs built a brand new course and attached million pond club houses to them to attract members against members golf course who at that stage were struggling to maintain their aged clubhouses.!!
Now maybe some of the balance has been reinstated!!
For whatever reason Golf is going through a difficult phase and i am sure there will be further casualties. New ways to develop the game and return people to it is required which means that ALL clubs should be pulling together for the good of the game and eliminate what I see as this petty bickering by some individuals!! As I said in opening comments, money returned to the game of golf is a benefit to the game and all that play the game
Nice story but unfortunately incorrect.
1. A high percentage of the proprietary clubs were purchased from the original land owners and to my knowledge your so called hand-outs were never passed down the chain.
2. How many courses with so called million pound clubhouses do you think are owned by the original investors or more importantly have eluded financial difficulty?
In my opinion, you are completely unaware or missing the point of what is actually going on.
As a private members clubs, you need to have a good look at yourselves…. how are your principles different when you operate no differently than a proprietary venue?
Are you telling me you don’t do any of the following?…. Actively sell green fees, memberships, societies, functions…need I continue?……Guess what….you then take advantage of paying less VAT, rates and corporation tax + all the other scams, licencing laws, casc, etc……and guess what… you don’t make a profit?!
In the current climate this is acceptable and a reality so what do private members clubs do?
You hit the panic button.. relieve the green keeper, the pro, or the hon sec of a few hours, get rid of the caterer for more favourable terms….. anything to avoid ‘real’ decisions and your objectives are ‘just keep a happy ship’!
However, if we have an upturn in fortunes and golf starts to thrive or maybe just look back 10-15 years ago when your so called ‘charitable balance’ (profit) of revenue was/will be used to improve your facilities, stop the fees from going up, purchase machinery, new showers, new changing room? HOW CAN YOU NOT SEE THIS IS WHAT IS ACTUALLY HAPPENING?
Pull together……..how can we pull together with such an unfair balance across the board?
In my opinion (for what it is worth) appears to have a relationship to the battle of Trafalgar in particular “Nelsons blind eye” only seeing what you want to see.
In my area there are four clubs of a significant nature, two of which are long standing members clubs the other two are new recently developed propriety courses which have both been developed from farming land in the last fifteen to twenty years where the members courses have been long standing.
Both the propriety courses looked at ways to change their income stream and at the time took advantage of government grants to develop their farm (business) in a new direction to create a new income stream (PROFIT) this I believe can be termed as “A BUSINESS” both of these clubs due to grant aid were able to build new clubhouses the first from the implementation of the club and the other within a few years of opening the course. and both of these clubs are STILL owned by the original landowner who developed the land into a golf club to make a PROFIT.
Now let us look at the members clubs which have operated in the same financial climate over a much longer period the one has invested in a new clubhouse in an attempt to maintain its business and is now in dire financial situation as they made the investment just prior to the recent downturn in the financial world and golf clubs in general. The other which was a little more prudent in its approach sill has its creaking old clubhouse which it has to continue to patch and mend through the financial winter of golf.
Yes we do sell green fees yes we do all the other activities which all golf clubs have to do and like all other golf clubs we are trying to stay in business.
We do not operate scams as you put it but are attempting to battle what in the past has been an un-level playing field against local propriety golf clubs which have had the BENEFIT of government money and are still owned by their original farmer developers who did so for PROFIT.
So I feel that I have to correct your comments regarding where you clearly state my comments are “INCORRECT”
The un-level playing field in the past has in my particular case been sloping towards new proprietary golf clubs and now the members clubs have had a rightful leveling the propriety club owners appear to be coming out of the wood work.
Your vitriolic rant above again is somewhat objectionable. As a members club we operate within the present UK law and always have done and do not operate scams or any other unlawful act.. May I ask you which propriety club you have a financial interest in to make a profit? My interest in my members club is given for free as a volunteer member of the committee.
Oh just one last point regarding your comment about corporation tax. If you are paying corporation tax which you appear to be as you are so vociferous about it you MUST be making a “PROFIT!!!!!”
As I said in my previous statement stop bickering and accept any money into golf at this time is a good thing and get on with improving the game of GOLF!!!!
Also if you fully understood the finances of the implications of the VAT on green fees post the implementation of the above by the time that members clubs have made the appropriate adjustment to the VAT on expenditure there maybe little difference in the final figures in the year end accounts. Maybe this is something you should investigate further before making too much of an issue of it!! Get your facts straight!!
Nicely written…I obviously must ask the question in a more transparent format! ‘In the event of an upturn in fortune or golf starts to thrive or maybe a view of your accounts 10-15 years ago… was there ever a positive balance?
And if so, what did you call it?
With regard to your question regarding “positive balances”. They were referred to and still are as RESERVES, which are never taken out of this member club. Any surplus funds when properly balanced are, as and when applicable are returned with prudence back into the club to maintain and improve the golf experience to both the members and our visitors alike . Not a penny is taken out of the club in the form of profit by any person associated with members club. Now I will ask you a question can you unequivocally make a similar statement for propriety clubs ?
Also you appear to have missed my previous question to you regarding to your interest with regard to any propriety club(s).
Is your driver on the subject as a member or as a person who has any financial interest in a propriety golf club? I do hope that the question is transparent enough to obtain a clear truthful answer.
A couple of points to the above comments, I’m involved with a proprietary club and can assure you we received no grants to diversify and I can not name you a club locally that did receive any. Could you tell me what these grants are/where for? Maybe I will be able to apply retrospectively for them.
The comment above about Members clubs investing in building new club houses, could these have been built by the last lot of money claimed back by ‘private’ members clubs? There’s quite a few clubs local to me that all have grand clubhouses built from the last bailout/payout.
Surplus and profit, a grey area? I would say the majority of proprietary clubs that make any profit (which is very few) roll any profit back into the business to improve facilities to try to compete with the ever more commercial ‘Private’ members club.
John Thank you for your comments, Regarding your points.
Obviously we all operate in a different local environment and from my point of view I am representing the ones which is local to me. My main point is that Members clubs are not in business we are in the game of golf to provide a service to our members and visitors alike we are not in the game of golf to make a profit from which to earn a living, which for me is a totally different ball game, as a result should be considered differently.
Both type of golf clubs go into the arena with different objectives and I would suggest both with our eyes open. What I find particularly objectionable is that some people make accusations on here that members clubs are operating scams etc . NO we are in it to provide a service to our members and visitors alike and give them a rewarding golfing experience and along the way promote and develop the game of golf within the local area.
Regarding your comment Surplus, profit. Whatever you like to call it in the case of members clubs this is all returned to the game of golf without a skim of profit being taken by the proprietor(s) this is a significant difference. It may be the case that the propriety golf course operates on the back of a country club where the whole leisure experience is focused an one business, this gives the ability of one sector of the business to financially support another in times of tough trading in a particular area. The members club does not have this facility certainly not in my area however I can name several such instances where this is the case in a propriety club environment Again a significant difference to operating conditions.
As a committee member I pay particular attention to the accounts (not as an accountant but as a retired management consultant) operating as either a members or as propriety club is no different it is all about income and expenditure, the way this is managed and controlled within a difficult operating environment is the same for all clubs and managed correctly there are difficult decisions to be made at all clubs which today may mean the difference between success and failure. I work closely with the club accountant who also completes the accounts for other local golf clubs whereas he maintains a professional approach to his comments he would reflect that my golf club is now well run down to a lot of work by the staff, guided by a professional management committee.
Should any club be managed well, then there are still profits and reserves available for the clubs which operate well. However to repeat myself, this is where the members club will return 100 % of these monies back into the game of golf and not operating to make an income for the proprietor, hereby in my mind making the difference for their existence and the way which they are considered between a members club and a propriety club. Which is a very good reason for members clubs being considered in a different light to propriety clubs.
There are lots of enterprises which co-exist operating in the same sector as each other where the one is operating for profit while the other is run by a group of volunteers and as a result are considered differently by several government agencies. So why on this occasion should some people be creating such a hullabaloo by what will turn out to be a very small amount of money as the rules of VAT exemption role out in the future??
llangolfer
We are obviously not going to agree on the workings of golf club finances, which is totally fine as everyone has their opinions. I’ve nothing against ‘Private’ members clubs and myself and my club is very friendly with many all over the UK. Having been in this industry from greenkeeping to running a club all my working life I am convinced the ‘traditional’ membership model of a club is now dead for at least 90% of clubs in this country (but that’s a post or maybe a letter to editor of GCM on another day).
What are your views on ‘Private’ members clubs hosting weddings, conferences, having function rooms or offering on site accommodation? Are these not in competition with local pubs and hotels which are closing nationwide daily? Do these add ons have anything to do with golf? There are hundreds of golf clubs claiming CASC (which was backed by England Golf) which entitles them to an 80% business rates relief. Some clubs local to me with are saving £20k-30k per year on business rates (which their committee members are very proud to spread the news of the saving they’ve achieved). They are all available to hire for functions of all kinds, is this fair? How can other local venues compete with this while paying full business rates?
As I said England golf pushed the scheme on their website and I believe either they (or county unions) wrote to/emailed clubs several years ago to recommend the scheme and the savings that could be achieved.
I’m not asking you to comment on individual clubs but have a look at Huddersfield GC’s website, particularly the weddings section.
http://www.huddersfield-golf.co.uk/
How can fixby hall be suitable for CASC? How much would their business rates be for their stately manor house without CASC subsidies? They are licensed to hold civil ceremonies there, how is this a community project? Do they offer very cheap wedding packages for local people? Or is it actually a very high profile exclusive venue?
CASC is supposed to be for community clubs, I would suggest Huddersfield GC is one of the most expensive in the area and am pretty sure that potential members could still be ‘blackballed’ if not suitable. So it is obviously not a community project and against CASC guidlines.
The other thing with Huddersfield GC is that the Yorkshire county golf union has it’s offices in it’s Fixby Hall clubhouse. Does this mean the Yorkshire golf union are also happy with the CASC registration and condone it? How can England golf and county unions claim to represent golf as a whole when they have alienated a large proportion of their membership?
I have researched every single golf CASC registration in the UK and would say there are no more than a dozen golf clubs that are claiming the scheme that have a genuine claim for it and not just using it as a business rates dodge.
John Hi!
I take your point regarding diversification and I am not aware as you appear to be on the CASC registration against the percentage of clubs which actually only operate as a golf club. My golf club is registered and only operates as a golf club.
I note that another local club to me is both registered with CASC and also operates as a wedding venue. Without delving into the terms of obtaining CASC I would not like to comment but I would suggest from what you say that this should be an area to be investigated. Having said that it is not illegal if you are avoiding tax within the parameters of the individual scheme what is illegal is tax evasion . What could be concerning for some of these clubs which have changed there model since achieving CASC if they have not checked with CASC to see if they still meet the guideline for the said accreditation then they could be leaving themselves open to a large bill for recovery of unpaid tax.
However when in major commerce a director of mine gave me a book to read named “The Focused Factory” in short it’s message was stay with the core business, stay with what you are good at and the company is more likely survive, get sidetracked onto spending a disproportionate amount of time and effort on ventures which you are not skilled in and the core business is likely to suffer. A prime example of this was the supermarket Sainsbury’s was by a league the largest supermarket chain in the UK, some years ago the diversified into two major enterprises one was Homebase and the other one escapes me. Tesco said thanks very much and romped past JS and became the largest supermarket chain in the UK and JS have never recovered the ground which they lost..
Returning to golf clubs, what is happening that as a result of the downturn in world wide golf the weaker clubs which do not have a good product or have a good product but are not maintaining it are the ones if miss-managed are the ones which go to the wall. Local to me two golf clubs have gone in recent years. Possibly one more to go in the near future, those that will survive are the ones which look after their members and their product the golf course.
Having worked both in the corporate environment and also operated my own business has made me realise that there are no friends within this commercial world. It is a dog eat dog existence, where any venture has to take every opportunity it can to maximise its income and minimise its expenditure and deal the best hand for it’s self as if the business isn’t be sure someone else is and therefore obtaining a commercial advantage.
llangolfer
At the end of the day a Private members club should be for the members and their guests if it wants to keep its tax free status. If it wants to advertise green fees for visitors, societies and corporate days then these have nothing to do with the members apart from keeping their subscriptions artificially low.
Although there is some good news on the CASC side of things, apparently HMRC has wrote to a number of CASC clubs last week, de-registering them from the scheme and there is also the possibility that local authorities will now chase the offending clubs for the monies that they should have paid.
John
A good point and that is why now that Members clubs are exempt from paying VAT tax on green fees they have lost their VAT tax exemption from on course expenditure which makes for a level playing field!! So we are not tax free and therefore I can only agree with you.
The over all effect of the above is that should they not sell enough visitor green fees to cover the cost of the above 20% on all on course expenditure they will be financially penalised by a factor of 20%.
So HMR&P have in fact put in place where members golf clubs now have to sell green-fees to visitors or have a NEW tax burden of up to £20K pounds per annum.(The figure is based on an average golf club course expenditure of £100K per annum). So the level playing field which some people are moaning about is not as level as it first appears.
Llangolfer
You think that proprietary/profit making clubs are in a better position in the market than ‘private’ members clubs? Is that what you are saying in your previous post?
John…finally, some sense and reality to this discussion… Will ‘llangolfer’ dare reply?
Will he recognise what the majority of his fellow private members clubs are actually doing?
‘Non – commercial Private Members Golf Clubs’………NOW SELLING…Weddings, funerals, functions, celebrations, corporate memberships, corporate golf days, board meetings with free Wi-Fi, Sky TV events, etc, etc!
‘What next’ or should I re-phrase….’coming soon to your private members club’…residential development, costa coffee, Nando’s or maybe a cinema?
After this…will private members clubs still remain charitable non profit making organisations?
llangolfer….Its all about the ‘RESERVES’? Priceless
This also isn’t as cut and dried as members’ clubs think because of the corporate and agency issue.
Bridport and KPMG misled the judge by failing to declare that the £92,000 of green fees for 2009 actually included at least 47 corporate days.
Wow….’another hand out to those that do little or nothing to improve participation of our sport’. Thanks for the open-minded comment Glynn ! That is a dreadful remark. Maybe you would have benefited from attending the Devon & Cornwall Golf Conference recently, along with the other 140+ attendees. How narrow minded; how do you think we survive if we don’t encourage participation ?!
Ian, unfortunately I’m based in Cheshire, if your meeting was closer I would have attended. In answer to your question… paying less in VAT, corporation tax and rates…..in my opinion gives you a more than adequate chance to survive.
Your profits are disguised and used to keep your club in the manner you wish or improve your facilities. This is unfair competition and to my knowledge is not permitted in any sport in any other European country. Why England? And why not a level playing field for us all?
Glynn, the attendance statement was more of a rhetorical statement, however whilst taking on board your financial points it was (in my opinion) your somewhat dismissive attitude in respect of doing little or nothing to improve participation that rankled with me. In the past year we have attracted over 130 new members at my club, with a huge amount of effort from all concerned. I know plenty of proprietary clubs that are more interested in the other aspects of their business ventures than they are in golfer participation. It is not for me to knock that quest, that is their business, but equally I don’t wish to be thrown into a somewhat ‘stereo-typed’ remark from what you experience in Cheshire. We will no doubt have to agree to disagree; the beauty of freedom of speech, whilst we still have it !!
Ian, could you please answer this final question? Are you actually stating that your recent membership drive was to improve golf participation or was the initiative implemented purely to replace people you have lost?
The later, would indicate a reactionary, narrow minded plight to keep membership fees and your precious club ‘the same’. This would enable your club to remain in it’s ‘cosy little bubble’ without much change and not upset the apple cart.
On the other hand, if you increased a healthy membership with 130 new people…Well done you… now that’s what I would call a participation improvement!
Morning Glynn….most certainly the latter. The Club does not have a ‘cosy little bubble’ proof of which could be obtained from the Head Pro, who has seen his retainer slashed; proof of which could come from the Head GK who has lost one of his workforce (that was only 5 in the first place); proof of which could come from the office which has witnessed the hours of the Asst. reduced !!
So, on this occasion I/the Club will take your praise and give ourselves a pat on the back as things look a little brighter going forward.
mike is quite right. Alan I am not sure it is an unjust pay day but it might be unfair. Glynn it is good to see that you don’t wear blinkers and recognise that no members club is doing anything to increase the participation in golf! Vivien good luck with the work you are doing and I hope you get the right result, By the way, our irrecoverable VAT will now go up each year so don’t worry, HMRC will get their money back in due course!
The Association of Golf Course Owners warned the Government in 1993 that they could not limit the VAT exemption to membership fees. We have been proved right. The judge who heard the original Bridport case, Colin Bishopp, heard the arguments in a direction appointment in the Royal Courts of Justice on 22nd January. He made it clear that the court had now realised that many of the VAT claims had wrongly included corporate days, food, drink and buggies and he agreed to the parties coming back to court for a 5 day hearing in June when these points could be argued. Four clubs are now involved as typical clubs and will be party to that hearing – Bridport, Wilmslow, the Glen North Berwick and Berkshire. He described the Berkshire as being different from the others in view of their claim in excess of £1 million and it is those clubs where they are looking at a reduction of 67% of the claim. HMRC is to point out an information sheet to deal with the various claims and in particular the points in the claims which are disputed. The exemption can only be for services supplied to ‘persons’ i.e. individuals and the situation of societies, corporate days and sales to booking agents are at issue. European law does not allow HMRC to exempt these fees. The original Bridport case did not disclose that the ‘green fees’ for the year given as evidence included these kind of fees.
The proprietary sector has not ‘lost its case’ as suggested. The Chipping Sodbury case established that there is distortion between the two sectors and the court has written in the last couple of months to those proprietary clubs involved in that decision. But the main point for proprietary clubs is that the Association of Golf Course Owners (AGCO) has a case against HMRC in the Royal Courts of Justice in London from 23rd to 26th March at which we are arguing the distortion issues. AGCO has 25 witnesses joining in on this case, from golf and other leisure sectors. We also have a complaint direct to the European Commission in place asking that the European Commission takes infringement proceedings against the UK because of the distortion in the VAT treatment of sport. This is supported by counsel’s opinion. The Association of Golf Course Owners has a team of solicitors and accountants working on these issues as volunteers. We are in touch with politicians in Northern Ireland and Wales, as well as England, and are continuing with our fight to give our members VAT exempt golf. Nothing we are doing is aimed at having any adverse effect on members’ clubs. Their exemption is enshrined in EU law. We are continuing to ask proprietary clubs for financial contributions towards the barrister’s fees in the court action. All preparatory work has been done by AGCO’s team of 25 volunteers. We are hoping to have several candidates standing at the General Election under the Reduce VAT in Sports banner. Our case is that it is clearly unjust for some people to get VAT exempt sport and others to pay 20%. It is absurd as if one tunnel of the Dartford crossing was VAT exempt and the other had 20% added. We all know which tunnel everyone would aim for, Sadly golf’s governing bodies refuse to provide financial support to the proprietary sector for our cases in the RCJ and Europe because they are so biased towards the members’ club sector.
I see all the comments from the proprietary clubs. I have managed both, however the case against hmrc on behalf off the proprietary was lost. Should our case have been won I am not sure all of you would commenting in the same way. I am personally not annoyed with the private clubs at all but with the system.
Maybe rather than distancing ourselves from each other would it not be good to try to work together for the better of golf.
It’s a shocker, England Golf and anyone involved in this decision should be ashamed. When are the authorities going to remove the blinkers and realise private members clubs operate no differently than ourselves? Another unjust pay out that will lead to further ‘unfair competition’ between private and proprietary clubs….. or more appropriately, another hand out to those that do little or nothing to improve the participation of our sport. Well done to all concerned!
We, along with all proprietary owned clubs, echo Alan’s comments below. Yet more bad news form the golf industry.
Private clubs receive another unjust pay day while us proprietary owned clubs are left behind once again! Completely unfair.
Agree, but my society for one will be claiming the vat element that we were charged by those involved – 15 events per year @ 30 members per meeting – how many years does it go back?
I hope that you have kept all your receipts!!
Society members have no right to any refund. Green fees were and are set at market rates, with golf clubs absorbing the VAT and not passing the burden on to those paying the green fees. You can try claiming, but claims will be unsuccessful.
I disagree, why should the golf clubs have my and my societies money that we have paid them. If any club applies to HMRC and gets a refund of VAT, then we in turn will be liable to claim off them…..end of!
You can disagree all you like, but you cannot fight facts. I reiterate, you can try claiming, but any claims will be unsuccessful as there is no requirement for any golf club to return what you perceive you overpaid. As I have already stated, golf clubs set green fees based on market rates and the VAT was absorbed by the golf clubs and not passed on to those who paid the green fees.
All the best on your quest, however, it will be a long and fruitless one.
Sadly, I disagree – many many years of running business’s and dealing with HMRC, means that Golf clubs should they have a VAT rebate will in fact be treated no differently than other business’s
Evidently you are not too up on this particular case, or any like it. How many clubs that you visited advertised their green fees with VAT? How many have, following green fees becoming VAT exempt, dropped their green fees the appropriate percentage (which, by the way, would not be 20% even if they did)? I certainly do not know of any.
Go back and look at M&S and their case with HMRC regarding socks. Might give you some insight into what is going to happen when you try and claim back your money.
We are obviously not going to agree, so i will end this thread now, as you are evidently more informed than any of my fellow accountants and managers
And you evidently more than a top 20 UK Audit and Accountancy firm, along with KPMG. But hey, why let the facts ruin your argument. I see you did not answer either of my questions, nor, I suspect, did you bother to look up the case I mentioned. Well, they do say that ignorance is bliss.