“…tions seriously and carefully was emphasised in R (on the application of Archer) v Revenue and Customs Commissioners [2019] EWCA Civ 1021, [2020] 1 All ER 716, [2019] 1 WLR 6355 (a different Archer case brought, I believe, by this appellant’s wife), by Henderson LJ at [94]:…”
“… statutory procedure provided an alternative remedy which should normally be pursued before the issue of judicial review proceedings: see [2019] EWCA Civ 1021, [2019] 1 WLR 6355. The taxpayer in that case had issued a judicial review claim as regards an accelerated payment notice. Some three weeks later, she made representations under …”