Questione giuridica chiave
Whether the 1977 replacement value for real estate capital gains tax must reflect market value realistically, including ancillary construction, development, and land-value adjustments.
Decisione estratta
The lower court must reassess the 1977 value because the statutory replacement value may not systematically understate market value; ancillary costs and possible land-value discounts must be examined.
Motivazione estratta
For harmonization-law purposes the replacement value is a fictional acquisition cost at the statutory date and must correspond economically to the market value at that date. A schematic method is allowed, but not one that generally produces systematic undervaluation. Ancillary costs and any land-value discount need verification.