Kernrechtsfrage
Whether amounts linked to a reserved right of residence/usufruct qualify as deductible permanent burdens under direct federal tax law.
Extrahierter Entscheid
No deduction is allowed because the taxpayers made no recurring payments; they merely had to tolerate the servitudes.
Extrahierte Begründung
Art. 33(1)(b) DBG covers actual permanent burdens with effective expenditures. A mere temporary diminution in value of the property is not a fictitious income deduction; the owner does not pay the beneficiary and instead experiences an unrealized increase in property value.