the civic information do you believe has been publicly disclosed your honor specifically we know for a fact that in the publicly file tax liens several entities other than appellants have been identified and that's exactly what the entity the amount of the alleged tax liability the jurisdiction a date and you know some basic information and the fact that a tax lien is filed against the tax payer would disclose that there's been clear that one of the obviously the tax payer is under investigation because they have been ok well let me refine the question it means that there is a claim by the government that the taxpayer money right there they're catching a lien of some county assessor's office can records office so it means to the extent you're under investigation because i arrest claim sales taxes let's be more specific doesn't mean that they're under an investigation with llants along with those other entities in a single lane you can extrapolate that the i r s has relied on those other entities return information for determining the tax liabilities  so what it just is is that their listing related alter egos on the tax line is that you're saying yes ok so from there we need to take the next step in conclude that that means it's a broader disclosure and it means that it discloses something about the specifics of an investigation as opposed to an allegation of status related status yes your honor now i want to be clear appellant are not saying that all of the return information related to these other entities all but two facts are disclosed policy the name of us taxpayers and just the fact that they are under investigation we don't necessarily have access to the irises determination of how they could be under investigation and a separate matter we don't know that i mean it could be under investigation in multiple investigations and you want to tie it to this particular investigation which apparently you cannot determine from the face of the leader you would file that were identified in the public past me that i think would you agree with me that sixty one dollars of three is pretty broadly written and the description attacks appear information includes the name of the taxpayer right yes and that they the tax lien list other entities how does that then tell us that they're under under any investigation let alone this one i mean isn't there a problem under sixty one dollars of three that that goes at i don't think we can make and an interpretation of the statute based on whether prior counsel did or did not do something in a timely fashion if they can conduct discovery they could be prior to these boy requests the parents have our title as any u s citizen or if he is to request certain documents and the i r s is entitle to exempt certain documents but boy it's clear that they are required to disclose the information requested a lot as an exemption applies and right in your stand that point in the argument is under exemption three if there's a statutory basis for an agency not just the i r s but any agency not to produce documents then they don't have to  can't you can't use korea to trump other law correctly your honor but under lampert it information public they have to disclose it and ok i get your point but just tease us out because you are saying you know you're entitled to make  before what all we're asking for right now is the entity the identity of the of those other entities and you had asked it was already publicly available widely the oil request and one of the the biggest concerns that parents have had from the get of th different argument than the sixty one dollars of three prohibitions or way because information's public that seems to be an argument that we can require the government to search through every county or county recorder's office in every county in the country and identify reserve time i still do but if i can just get a couple points and then over the rest of my time i we've been focusing on the documents that have been exempted or the irises claim that exemption over it but taking a step back there's there's there's a whole host of documents that the iris did not meet its burden in under four years and specifically with regards to its disregard of about one hundred and ten thousand dollars pages of documents that it simply disregarded did not claim a single for all the sixty five boxes that contains eight hundred and forty one thousand who just are you claiming you want to discover all of that through for you s has disclosed or identified exemptions for only about thirty one thousand pages of documents and so extrapolating from the fact that there were one hundred and forty one thousand pages of documents there's a whole there's a one hundred and ten thousand page eighteen aside from the five plus the included in the five your honor we are seeking that information to the extent that we're seeking the identities of the documents the identities from anything to do with these entities or even by mistake so that would be my primary points just don't know why i didn't die in their exchange something that's completely separate from any more of these five companies for purposes of collection we believe that we should be able to go after them for purposes of collection purposes of sixty one of three they have not been found some possibility that we you know are going to succeed in going after them later there's also the possibility that these parties go forward and say hey we've managed prove that we're not the alter egos in which point we've automatically violated  would still be releasing from wanted to rd parties without there are resumption and the fact of the matter is if in fact these are alter egos it should really be hard for the companies who have the identification all of these to the extent they agencies to put forward time place manner requirements including access requirements and here he said look if you want to get the information of our party you need to provide either our tourney  was provided by the party by the private party as part and in fact one thing that was very interesting to me was that you know the whole opinion was really about the question about should we be able to get all this information about the start parties and the court said yeah you're not alter egos are not included in sixty one of three in one g so no you can't get that information i must have find you can't get under sixty one of three  information because whilst only to the extent it's actually been revealed and in litigation and the fact the fact that any given entity is in revenue officer blocks file they're being correct that the parties submitted that information to the court they said here's a bunch of companies the government did not reveal any information so what that would mean is in any litigation is a party could file the names acting for taxpayers if some other person can just list your name in a court filing which is what happened exactly what had government did not disclose that so appointed an action or defendant an action list somebody is named and now all and if in fact legal action goes forward involving these these these companies they can try to see the discovery process at that point in time and then extends term and then they commit analysis as to what documents but i don't just because i don't have a short amount of time i want to focus on what is included in section six hundred and three definition of what is return information and that includes any data received by recorded by furnished to or collected by the secretary with return with to the determination of the existence or possible distance of liability for any person under this title what that means is that to the extent that officer black co mingle and he's documents this was data he received or collected to be a term impacts liability exactly what a parent's requested so this parsing of words as to what is an administrative file is just it's just a very narrow way for the iris to avoid having to account for all the documents that it has d disclosed and to the extent dr i see my time is up your honor