Kernrechtsfrage
Whether including the 1997 rental income in the 1999/2000 cantonal tax assessment was arbitrary under cantonal law on intermediate taxation.
Extrahierter Entscheid
No arbitrariness: the Valais rule limited intermediate taxation to major changes in wealth or earning base, and acquisition or sale of real estate did not have to trigger it.
Extrahierte Begründung
Under the praenumerando system, timing gaps are inherent; income may be taxed later even after it has ceased, and the delayed taxation is offset by the delay when the income first arose.