Income tax – Avoidance. In considering whether to give an accelerated payment notice (APN), and so reverse the effect of a postponement agreement, the Revenue and Customs Commissioners had to consider that result from a base that it had identified a tax dispute and Parliament had provided that postponement was no longer governed by the existence of the taxpayer's side of the arguments relating to it. Accordingly, the Administrative Court dismissed the claimants' application for judicial review of the defendant's issue of APNs after entering postponement agreements.