“…J. The need for HMRC to consider representations 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]:…”
“…nce and held that this 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 rep…”
“…ght to make representations is of little real value because HMRC is not an independent judicial body. As this court held in R (on application of Archer) v HMRC [2019] EWCA Civ 1021, [2019] 1WLR 6355 (Henderson LJ at [94]):…”