Questão jurídica principal
Whether the transfer value of the house to private assets was correctly set for direct federal tax liquidation gain purposes.
Decisão extraída
The valuation used by the lower authorities was deficient; the case had to be remanded for a new assessment of the relevant market value and liquidation gain.
Fundamentação extraída
The court held that the official valuation could generally be used, but deviation from it required persuasive reasons. Here the 50% uplift over the cantonal valuation was insufficiently justified, the earnings value had not been properly included, and demolition/disposal costs linked to the ban on pig farming had to be considered.