Questione giuridica chiave
Whether first-time bonus payments received in 2000 during the assessment gap are extraordinary income subject to annual tax.
Decisione estratta
Yes. First-time bonus payments in the transitional year 2000 are extraordinary income and are taxed with a full annual tax.
Motivazione estratta
The court applied criteria such as first-time nature, unusual character, lack of changed accounting practice, and the taxpayer’s ability to influence payment. Both bonuses were paid for the first time in 2000, were not based on established contractual rules, and were significantly controlled by X.