Income tax – Profits. In dismissing the taxpayer's appeal, the Upper Tribunal (Tax and Chancery Chamber upheld the decision of the First-tier Tribunal (Tax Chamber) that the profit of £2.21m realised by the taxpayer following the sale in the market of a floating-rate promissory note was profit of an income nature, subject to income tax in the taxpayer's hand, under Case III of Sch D to the Income and Corporation Taxes Act 1988.