Kernrechtsfrage
Whether property x had been withdrawn into private assets by the taxpayer's bookkeeping treatment.
Extrahierter Entscheid
A private withdrawal requires an explicit, unambiguous bookkeeping treatment that is clearly communicated to the tax authorities. Here, property x was not listed among private properties and no clear disclosure supported a private classification.
Extrahierte Begründung
Up to 1986 the property was clearly business assets. Although private properties were listed separately in the accounts, property x was not included there. The bookkeeping therefore did not unmistakably characterize it as private property, and there were no external indications known to the authorities that would support such a classification.