Kernrechtsfrage
Whether the sale proceeds from the shares in B.P. AG were covered by a tax-office assurance of a tax-free private capital gain.
Extrahierter Entscheid
No binding assurance of a tax-free private capital gain for the shareholders was established.
Extrahierte Begründung
The written records and communications concerned only the company and its restructuring. They did not contain a confirmed statement by the competent authority on the shareholders' private taxation, and the taxpayers could not prove such an assurance.