“…clined to hear the claim, on the basis that there was no longer a live issue to determine. I accept that Elisabeth Laing J decided in R (Dunne and Gray) v HMRC [2015] EWHC 1204 (Admin) that a judicial review of an APN would not be rendered nugatory if the tax was paid (see [25]), but that is just one case on its own facts. The broad discretio…”