The High Court will decide tomorrow if bankrupt businessman Seán Quinn Snr is to be jailed for contempt.
Lawyers for Mr Quinn had earlier made what was described as "an impassioned plea" to the court not to jail the 66-year-old former billionaire.
Eugene Grant, QC, told the court Mr Quinn had made real and tangible efforts to purge his contempt by assisting the former Anglo Irish Bank to recover assets from the Quinn's International Property Group.
He still denies breaching any court orders preventing asset-stripping of Quinn companies.
However, IBRC said the submissions made on behalf of Mr Quinn Snr did not address the issues the court had to consider today.
Senior Counsel Shane Murphy said the question for the court was whether or not he had purged his contempt of court orders and the answer was "no".
Mr Murphy said it was clear from the submission made on Mr Quinn Snr's behalf that he still did not accept the finding of contempt made against him last June.
He added the court must make a decision based on those findings.
Mr Grant said Mr Quinn Snr admits he initially sanctioned a scheme to keep assets for the Quinn family, but did not breach any court orders.
He said Mr Quinn Snr believed he had suffered a grave injustice at the hands of Anglo having been fraudulently induced into borrowing money to buy shares which were on the brink of free fall.
He said the loan contracts were tainted with illegality and are void.
Mr Quinn Snr’s age and medical history should also be taken into account by the court, Mr Grant said.
He said the once leading light of the Celtic Tiger was brought down by the collapse of Anglo.
He was now bereft of any financial or economic dignity as a bankrupt.
Mr Quinn Snr had said the contempt hearing had a devastating effect on his family and the jailing of his son had been very difficult for him.
He wanted to deal with any punitive measure the court may impose for contempt today and was not seeking to adjourn it.
Mr Murphy said the case was one of civil and not criminal contempt and he disagreed with the recent finding by Supreme Court judge Adrian Hardiman that it was a summary criminal trial.
He said there was no automatic right to a stay on any order sending him to prison but the bank would not object to a stay pending an appeal to the Supreme Court, should the High Court decide to jail him.
Ms Justice Elizabeth Dunne said she would give her decision tomorrow morning.
Earlier, lawyers for IBRC said it continued to encounter fraudulent activity and delays orchestrated by the defendants which made it extremely difficult for IBRC to recover assets.
IBRC also believes the Quinns "have chosen to mislead" the court by withholding information and maintaining an entirely false position about the control and ownership of certain companies.
The bank must now engage local specialists to assist in asset recovery in Russia, the court heard, as IBRC had exhausted every possible legal avenue open to it, acting alone, to recover the assets.
The bank's interests may be irretrievably damaged, Mr Murphy said.
At the opening of the hearing this morning lawyers for IBRC said they will not be addressing the court on certain coercive orders made by the High Court last July in the light of a recent Supreme Court judgment which said proper procedures had not been followed by the High Court in enforcing those orders against Seán Quinn Jnr.
Mr Murphy told the court there will have to be a recalibration of coercive orders made by the High Court in the light of the recent Supreme Court judgment.
It was still open to the court to impose punitive measures against Mr Quinn Snr but that could be dealt with today or on another day, the court was told.
In July, Ms Justice Elizabeth Dunne found the father and son and Peter Darragh Quinn had not complied with orders to reverse the asset-stripping of Quinn companies.
She jailed Mr Quinn Jnr for three months, a sentence upheld by the Supreme Court.