Question juridique clé
Whether the company had its effective corporate tax domicile in V.________ or remained in W.________ for 2001.
Solution extraite
The company proved, just barely, that its actual management had moved to V.________; Lucerne failed to prove that the effective management still took place in W.________.
Motifs extraits
Although the new seat was in a private apartment with limited infrastructure, the special circumstances of this small company and the overall indicia sufficed to establish real management at the new location. Lucerne's evidence showed continued production and ordinary administration in W.________, but not that the decisive leadership activity remained there.