I may be wrong but I think Livingston differ from Gretna in the fact that they are not paying SPL wages in the 3rd division. David Bingham earned more at Gretna in the 3rd than at Livi in the SPL (fact...well maybe fact...well it was a widespread rumour at the time)
If Livi could get rid of all the higher earners they have I am pretty sure they would...as they found out with Dorado, you can't just cut peoples wages when you get relegated.
Point on the tax man still stands and I hope the club have been honest with the fans over a repayment schedule.