Her Majesty's Revenue and Customs (HMRC) has confirmed it will contest the decision of upper tier judge Lord Doherty in dismissing an appeal against a first-tier tax tribunal (FTT) decision in the so-called Big Tax Case.
HMRC has always argued the payments should be taxable but Sir David Murray's Murray International Holdings (MIH), which formerly owned Rangers, has twice successfully argued that they were loans and therefore exempt.
Furious Rangers fans maintain the case was the catalyst for the club's disastrous sale to disgraced venture capitalist Craig Whyte and subsequent liquidation and fall into the third division.
And the Union of Fans, which is a leading supporters group, said the reason for the pursuit of a "phantom tax debt" by HMRC, which it had now been proved had no foundation, should be investigated at the highest levels of government.
It has been examining legal action to right "the wrongs done to Rangers".
HMRC have applied to the upper tribunal to appeal to the Inner House of the Court of Session for permission to pursue another appeal.
"HMRC continues to believe that schemes using Employee Benefit Trusts to avoid tax do not work," said and HMRC spokesman.