Questione giuridica chiave
Whether the cantonal authorities arbitrarily found that hidden reserves were released during the business cessation.
Decisione estratta
No. The gross-profit comparison provided a sufficient indication of hidden-reserve realization, and the factual finding was not arbitrary.
Motivazione estratta
Willfulness in factual findings requires manifestly incorrect evidence assessment. The average gross margin for 1993-1996 was 9.57%, while the margin in the assessment gap was 12.98%, with a particularly marked deviation in 1998 when the activity ended. The taxpayer's explanation was contradicted by the market data.