Questione giuridica chiave
How should hidden equity be calculated for an undercapitalized company and how is the property classified for that purpose?
Decisione estratta
The hidden equity reallocation was correct because the imposed amount stayed within the range regardless of whether the property was treated as a factory property or an ordinary property.
Motivazione estratta
The court held that the exact classification could remain open, since the resulting maximum hidden equity under either applicable loan-to-value ratio still exceeded the amount actually reallocated.