Income tax – Pension. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) upheld a decision by the First-tier Tribunal (Tax Chamber) that a loan made to a taxpayer by a lending company had been an unauthorised payment for the purposes of the Finance Act 2004 and accordingly, the taxpayer had properly been subject to an unauthorised payments charge pursuant to s 208 of that Act and an unauthorised payments surcharge pursuant to s 209 of the same Act. Accordingly, the tribunal dismissed the taxpayer's appeal against an amendment to his tax return for the relevant year.