As the House of Lords observed in R v Inland Revenue Commissioners, ex parte Preston [1985] AC 835, judicial review will not normally be granted where an alternative remedy is available. In most cases, the remedy of a taxpayer lies in the appeal procedures provided by the tax statutes. The taxpayer will be expected to use the appeal procedure rather than resort to judicial review. Preston was able to bring a judicial review because the appeal procedure did not operate in circumstances of his case.