Questão jurídica principal
Whether alleged post-construction expenses for the attic apartment were proven and deductible in the property gain calculation.
Decisão extraída
The taxpayer did not prove additional post-completion expenses; the tax authority could rely on the substantiated property valuation basis.
Fundamentação extraída
No invoices or construction accounts were available; the documents and arguments indicated that the second apartment had largely already been fitted out in 1981. The anticipated witness evidence was unlikely to clarify costs after more than twenty years. The statutory 50% uplift of the cadastral value sufficiently covers possible later value-enhancing expenditures.