Key legal question
Whether the land parcels in S./AG belong to business or private assets
Extracted holding
The parcels are attributable to the taxpayer’s business assets because he used his building-engineering expertise in a systematic, planned real-estate activity aimed at profitable resale.
Extracted reasoning
His main occupation was self-employment in the construction sector; acquisition, financing, holding and sale of the parcels were closely connected to that activity and its specialized knowledge.