Questione giuridica chiave
Whether the sale qualified for tax deferral for replacement of self-used residential property under Art. 12(3)(e) StHG.
Decisione estratta
No deferral was due because the sold property had been rented out for more than two years and the replacement-sale timing exceeded the cantonal two-year period without exceptional circumstances.
Motivazione estratta
The cantonal two-year replacement period harmonized with federal law; the taxpayers largely caused the delay themselves, and a long prior rental period meant the sold property was not 'continuously and exclusively self-used'.