Questão jurídica principal
Whether the Rückweisungsentscheid bound the authority and court as to the permissible method and amount of the back-tax estimate.
Decisão extraída
The earlier federal judgment bound the authority only to the extent that the full CHF 140,000 could not be attributed entirely to 2007 income; it did not require a specific partial allocation for 2007. Within the estimation margin, the authority could spread the amount over the back-tax period.
Fundamentação extraída
The scope of binding effect depends on the tenor and rationale of the remand. A partial allocation to 2007 was permissible but not mandatory, and the lower court erred by effectively reverting to the rejected view that the whole amount belonged to 2007.