Income tax – Corporation tax. The Upper Tribunal (Tax and Chancery Chamber) dismissed the taxpayer's appeal against a decision of the Revenue and Customs Commissioners to reject the joint election pursuant to s 171A of the Taxation of Chargeable Gains Act 1992 made by the taxpayer and another company within the same corporate group (GR) to deem the disposal of certain loan notes issued by a third party company to the taxpayer as having been made by GR rather than the taxpayer.