· By his own admission, Mr. Hamersley worked in mergers and acquisitions and was not involved in the provision of tax services related to corporate tax strategies. He had little or no experience in that area, nor in testing of client's tax accruals on financial statements. In other words, he is simply not qualified to reach the purely personal opinions he espouses about alleged improper or so-called "abusive" activity. His conclusions are simply wrong.

· The specific purported issues as articulated by Mr. Hamersley were in fact taken seriously, were investigated, and were reviewed thoroughly by more experienced and expert tax and audit personnel at KPMG. In each and every case, Mr. Hamersley's allegations were found to be without merit and his analysis to be flawed.

· Mr. Hamersley's testimony consists largely of generalized speculation, personal opinion and unsupported allegations. His conclusions are simply wrong.

· KPMG understands that times have changed and that the tax rules are changing too. Our tax practice is continually evolving to meet changing circumstances. We have enhanced our professional training programs and intensified quality control, and have also restructured and reorganized our tax groups to reflect these changes.