Kernrechtsfrage
Whether the land gain on the sale of parcel D.________ was taxable as income from self-employment or tax-free private capital gain.
Extrahierter Entscheid
The gain was taxable as income from self-employment because the taxpayer acted systematically, with profit intent, and in close connection with his architectural business rather than merely managing private assets.
Extrahierte Begründung
The court relied on the overall course of conduct: planned development efforts, use of the controlled architecture company, repeated attempts to secure the project, contractual compensation for the lost architectural mandate, and the conversion to sole ownership before resale.