Key legal question
Whether immediate write-offs made under former Aargau law after a replacement acquisition must reduce land-gain tax basis or be taxed as income.
Extracted holding
The old immediate write-offs remain taxable as income; they do not reduce the acquisition costs for future land-gain tax purposes.
Extracted reasoning
Under Art. 12 StHG, all depreciation included in book value is to be considered in acquisition costs, regardless of whether it arose from ordinary depreciation or a replacement-acquisition write-off. The cantonal solution is compatible with harmonization and with the distinction between income from self-employment and land-gain tax.