Question juridique clé
Whether the property gains tax lien had lapsed because the request for registration was filed too late.
Solution extraite
The lien right had not lapsed because the statutory three-month registration period ran from tax due date and the lien was entered within that period.
Motifs extraits
The tax became due upon service of the assessment notice; the lien was registered on 12 August 1991 after the 16 May 1991 assessment, thus in time under § 59(4) StG.