Kernrechtsfrage
Whether the 28 October 1994 registration of the inheritance-sharing transfer was the taxable alienation event.
Extrahierter Entscheid
Yes. It was not arbitrary to treat the land-registry transfer on 28 October 1994 as the taxable realization event, even if other partition steps continued later.
Extrahierte Begründung
Under the former cantonal law, gain tax is triggered by alienation, including transfer of a co-ownership share. In a succession partition, the registered transfer can be treated as the relevant event independently of later partition formalities, and the registration had not been annulled.