Key legal question
Whether a waiver of a loan claim is a taxable gift under cantonal gift tax law.
Extracted holding
Yes. The waiver of a receivable relieves the debtor from repayment and therefore constitutes a gratuitous enrichment; it is taxable as a gift.
Extracted reasoning
Under § 233(1) StG, gift tax covers inter vivos transfers without consideration. A debt waiver reduces liabilities and benefits the recipient economically; whether the farm value increased is irrelevant.