Questão jurídica principal
Whether the refusal of party compensation for the direct federal tax proceedings before the tax review commission was lawful.
Decisão extraída
The refusal was unlawful; for direct federal tax, the court had to apply Art. 144 DBG in conjunction with Art. 64 VwVG and assess necessity case by case.
Fundamentação extraída
The cantonal rule could not replace the federal cost regime. In this case, the question of tax residence and the taxpayer's need to understand evidentiary and procedural duties made legal representation necessary.