Kernrechtsfrage
Whether the transfer of the real estate qualified as a tax-free hand change in inheritance division under § 207 Abs. 1 lit. a StG.
Extrahierter Entscheid
The transfer was made in the course of inheritance division, so no hand change tax was owed.
Extrahierte Begründung
The heirs had not formed an ordinary partnership; the evidence showed only administration and liquidation of the estate, with attempts to divide it over time and no proven express or implied partnership agreement. The late completion of division did not by itself transform the inheritance community into a simple partnership.