Questão jurídica principal
Whether the cantonal court erred in allocating procedural costs after the partial success on the tax merits.
Decisão extraída
No. The taxpayers were only partially successful, so allocating the costs largely to them was consistent with federal tax law and did not exceed discretion.
Fundamentação extraída
The earlier Federal Supreme Court judgment had not granted the appeal unreservedly; it had only required taxation of the buyout's income component. The appellants had sought full exemption and therefore remained largely unsuccessful.