Kernrechtsfrage
Whether the gain from the 2000 sale of the parcel constituted extraordinary income subject to transition annual tax
Extrahierter Entscheid
Yes. The gain was an aperiodic capital gain realized on long-held business assets and therefore taxable by annual transition tax.
Extrahierte Begründung
The parcel had been held since 1993 and always booked as fixed assets. The gain stemmed mainly from market-driven appreciation, not from the taxpayer's ordinary architectural business. Such a realization of hidden reserves is aperiodic rather than ordinary.