Kernrechtsfrage
Whether the proceeds from the partial sale of the wine collection were taxable income from self-employment or tax-free private capital gain
Extrahierter Entscheid
The collection had been built at least in part with a view to later profitable sale; the 1997 proceeds therefore constituted taxable income from ancillary self-employment.
Extrahierte Begründung
The Court applied the general criteria for distinguishing private asset management from self-employment to a wine collection. The size of the stock, prior profitable sale, repeated purchases, specialist knowledge, planned liquidation at a wine festival, and the impracticality of merely consuming such quantities indicated a systematic profit-oriented activity.