Questão jurídica principal
Whether the property gain tax claim was time-barred
Decisão extraída
The claim was not time-barred; even under the older cantonal rules the limitation was interrupted, and application of the newer 15-year rule was not unlawful.
Fundamentação extraída
Limitation is a substantive institute, but the old law contained no specific rule for this tax. Analogy to the cantonal introductory civil code and interruption rules showed no expiry. In any event, later procedural steps interrupted or suspended the running period, and the delay in opening the reasoned lower-court decision did not extinguish the tax claim.