Kernrechtsfrage
Whether the handänderungssteuer assessment against the sellers was unlawful because the buyers were the tax debtors under cantonal law and the contract.
Extrahierter Entscheid
No. The contract validly authorized the sellers to represent the buyers and receive the assessment, and the later objection decision made clear that the buyers were the taxable persons.
Extrahierte Begründung
The court found the contract clause unambiguous: the sales party would bear the costs, but the buyers remained liable to the state; the sellers were authorized to represent them and receive the tax notice. The omission of the buyers' names in the original assessment was cured in the objection decision, which expressly named the buyers as taxpayers represented by the sellers. The appellate decision also made clear that the sellers were only acting as representatives.