Income tax – Pension. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) dismissed the appeal by the taxpayers against a decision of the Revenue and Customs Commissioners that it was just and reasonable for the taxpayers to be liable for unauthorised payment surcharges under s 209 of the Finance Act 2004 in respect of payments made to them in relation to a Bespoke Pension Trust scheme entered into by the taxpayers into which their pensions had been transferred. In the tribunal's view, the taxpayers had not acted reasonably in relation to entering the scheme nor receiving the unauthorised payments.