Kernrechtsfrage
Whether the claimed loss from the 2007 farm transfer could be carried forward and offset against 2008 income under Art. 67 StHG and § 38 StG/AG.
Extrahierter Entscheid
No. Losses may only be carried forward to the extent they could not already be offset in the earlier period; a loss denied in a final prior-year assessment cannot be relitigated in later years.
Extrahierte Begründung
The court held that Art. 67 StHG and the period principle require prompt loss offsetting. If taxable income existed in the earlier period, losses cannot be deferred arbitrarily. Any challenge to the denial of the 2007 loss had to be raised against the 2007 assessment, which became final.