Hemmin, thought you said you were a lawyer?
Even though the old club, sorry, company is dead, the decision was appealed by HMRC mainly for three reasons:
a) To set legal precedent
b) To assure creditor status on the approx. £30 million being held in escrow by BDO, the liquidators of Rangers.
3) To gain authority to force repayment of loans and/or taxes by employees that benefitted from the EBTs.