Question juridique clé
Whether the gain on sale of the parcel qualified for deferral under the reinvestment rule for land acquired to build one’s home.
Solution extraite
No deferral: the taxpayer did not make it plausible that, at acquisition in 1973, she had bought the land with the firm intention of building her own dwelling.
Motifs extraits
For non-built land, the statute required plausibility of acquisition for home construction. The cantonal court could, without arbitrariness, infer from the long delay before construction steps and the circumstances of the acquisition that such intention was not established at the relevant time.