In Conroy v Deputy Commissioner of Taxation [2005] QSC 206 the appellant contended that the Governor- General was appointed by commission by the Queen as Queen of Australia and that there is no-one answering that description having any legal role in the constitutional or legal affairs of this country, and that the Great Seal of Australia is not the correct seal for use by the Queen. Further, the appellant contended that as the name Bevan Conroy was in capital letters on the notice, the proceedings are in some way invalid, as his name capitalised refers to a body corporate or person.