Key legal question
Whether the two-year occupancy deadline for transfer tax exemption on undeveloped land can be extended.
Extracted holding
Yes. The court held that the two-year period under the implementing regulation is only a guideline and may be extended in exceptional cases, including delays caused by a zoning revision outside the taxpayers' control.
Extracted reasoning
The project was continuously pursued, and part of the delay stemmed from the municipality's zoning revision, which was outside the taxpayers' influence. The regulation must not be interpreted narrowly so as to defeat the exemption where self-use was intended from the outset.