Income tax – Partnership. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) dismissed the appeal by the Revenue and Customs Commissioners against a decision of the First-tier Tribunal (tax Chamber) which had allowed the taxpayer's claim for deduction of a payment made to a bank on the basis that it had been am expense incurred 'wholly and exclusively for the purposes of the trade' as required by s 34 of the Income Tax (Trading and Other Income) Act 2005. The tribunal held that it was in the context of the limited liability partnership (LLP) conducted collectively that the taxpayer had to justify the deduction of his payment and that the payment at issue had not been incurred 'wholly and exclusively' for the purposes of the LLP's trade.