Kernrechtsfrage
Whether attorney and asset management costs are deductible as administration costs for movable private assets under § 39 Abs. 1 StG.
Extrahierter Entscheid
Such costs may be deductible if they qualify as third-party administration costs for movable private assets; attorney costs incurred to safeguard assets can fall within that category.
Extrahierte Begründung
The court referred to § 39 Abs. 1 StG and held that administration costs for movable private assets are deductible. It also accepted, in principle, that legal fees incurred to secure assets can count as deductible asset management costs.