 and they were unequivocally realizing income, right? So this idea that their income was not taxable, or that their stake in this company was not taxable the way it was being taxed, it was just incommiserate with the actual facts on the ground. And that's something we're seeing in a bunch of these cases, right? The facts, as alleged, are not the facts as reality manifests them, right? So this was something we saw, I think, pretty conspicuously in Brenner...