(3) Where, in an appeal under this Act, a penalty assessed by the Minister under this section or section 163.2 is in issue, the burden of establishing the facts justifying the assessment of the penalty is on the Minister.
The number of days in your cycle is calculated by counting the number of days from the beginning of one period to the beginning of the next period. If you have a short cycle, for example 21 days, and you bleed for 7 days, then you could ovulate right after your period.
If a woman has a nice regular 28 day cycle and a 4 day period, that means that she will ovulate 14 days after her last period started and 14 days before her next one is due. That also means there will be at least 9, probably 10, days after her last period ends before she ovulates.